• Elections to Defer Estate Taxes under IRC Section 6166 - IRS Announces Standards for Seeking Security
  • August 25, 2009 | Author: Frederick M. Sembler
  • Law Firm: The Law Office of Frederick M. Sembler, PLLC - New York Office
  • Ordinarily, United States estate taxes owed for a decedent's estate are due within nine months from the date of the decedent's death. Under Section 6166 of the Internal Revenue Code, however, the executor may elect to defer payment of the estate taxes attributable to those interests for a period of up to 14 years from the generally applicable due date. On October 29, 2007 the IRS issued Notice 2007-90, in which, among other things, the IRS set forth a "non-exclusive list" of factors that the IRS will review for the purpose of determining whether security should be required from an estate in order for a Section 6166 election to be allowed. In January 2008, The Law Office of Frederick M. Sembler, PLLC, submitted comments to the IRS concerning Notice 2007-90.