PLR 8846001 - §6166(h) Computation Illustration 4

IRS Holding For The Amount Of Tax Deferred Under The §6166(h) Election

Finally determined estate tax182,736.60Section 6166(a)(2) ratio - maximum amount of tax payable in installments (carried to 6 decimal places pursuant to the current Instructions for Form 706)74.1835%Maximum amount of tax that could have been deferred under §6166 (rounded down to the amount stated in the PLR)135,560.36Portion of the §6166(a)(2) Maximum Amount Not Eligible For the §6166(h) ElectionTax originally assessed for which neither a §6166 election nor a protective §6166 election was filed115,287.42Section 6166(a)(2) ratio - maximum amount of orginally assessed tax that could have been payable in installments74.1835%Portion of the originally assessed tax that could have been deferred with a §6166 election or a protective §6166 election, but which does not qualify for the §6166(h) election85,524.24Portion of the Deficiency That is Eligible For the §6166(h) ElectionDeficiency67,449.18Section 6166(a)(2) ratio - maximum amount of tax payable in installments 74.1835%Maximum amount of the deficiency that is payable in installments50,036.16ReconciliationPortion of the originally assessed tax that is not eligible for a §6166(h) election85,524.24Portion of the deficiency that is eligible for a §6166(h) election50,036.16The maximum amount of tax that could have been deferred under §6166 (rounded down to the amount stated in the PLR)135,560.36IRS's Calculation of the Annual InstallmentTotal tax deferred under section 616650,036.16Number of installments elected10Annual Installment5,003.62IRS's Calculation of the Annual Installments Payable Under the §6166(h) ElectionInstallment NumberDatePrepayment Credit AvailableAnnual Installment DueAnnual Installment Payable1Feb-17-19860.005,003.625,003.622Feb-17-19870.005,003.615,003.613Feb-17-19880.005,003.625,003.624Feb-17-19890.005,003.615,003.615Feb-17-19900.005,003.625,003.626Feb-17-19910.005,003.615,003.617Feb-17-19920.005,003.625,003.628Feb-17-19930.005,003.615,003.619Feb-17-19940.005,003.625,003.6210Feb-17-19950.005,003.625,003.62Total payments50,036.1650,036.16