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with the liquidity problems experienced by estates in which a
substantial portion of the assets consist of a closely held
business”. H. Rept. 94-1380, at 30 (1976), 1976-3 C.B. (Vol. 3)
735, 764; and see Estate of Bell v. Commissioner, supra at 902
(“The purpose of section 6166 is to prevent the forced
liquidation of closely held businesses because substantial estate
taxes must be paid.” (citing H. Rept. 94-1380, supra at 30, 1976-
3 C.B. (Vol. 3) at 764, and S. Rept. 94-938 (Part 2), supra at
18-19, 1976-3 C.B. (Vol. 3) at 660-661). Congress was concerned
that “In many cases, the executor is forced to sell a decedent’s
interest in a farm or other closely held business in order to pay
the estate tax.” H. Rept. 94-1380, supra at 30, 1976-3 C.B.
(Vol. 3) at 764. Allowing the Commissioner to impose a mandatory
bond requirement exacerbates the problem that Congress was
dealing with in enacting the statute. Estates such as the one in
this case have liquidity problems that would make it difficult
not only to pay tax but also to secure a bond. Also, the closely
held nature of the small businesses that give rise to the
election may make it more difficult for these businesses to be
able to offer to secure their assets with liens. This does not
mean, however, that the financial risk is too great to allow the
estate to pay its tax in installments. The record in this case
suggests that the executor is a wealthy, well-respected
businessman; that the businesses giving rise to the election are
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