Extension of Time to Pay Estate Tax

ID: CCA_2011101110042947 Number: 201142024
Release Date: 10/21/2011
Office: ---
UILC: 6166.00-00
From: ---
Sent: Tuesday, October 11, 2011 10:04:31 AM
To: ---
Cc:
Subject: FW: 6166 question
Hi ---I would not think this would accelerate the section 6166 election. 6166(g) applies where the interest in a closely held business is "distributed, sold, exchanged, or otherwise disposed of". This is broad language meant to encompass different ways that interest ceases to form a part of the gross estate. A change in the form of business holding the subject property would not qualify as a true divestment of the interest in the property from the gross estate.