PLR 8846001 - §6166(h) Computation Illustration 4 IRS Holding For The Amount Of Tax Deferred Under The §6166(h) Election | ||||
| Finally determined estate tax | 182,736.60 | |||
| Section 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) | 135,560.36 | |||
| Portion of the §6166(a)(2) Maximum Amount Not Eligible For the §6166(h) Election | ||||
| Tax originally assessed for which neither a §6166 election nor a protective §6166 election was filed | 115,287.42 | |||
| Section 6166(a)(2) ratio - maximum amount of orginally assessed tax that could have been payable in installments | 74.1835% | |||
| 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) election | 85,524.24 | |||
| Portion of the Deficiency That is Eligible For the §6166(h) Election | ||||
| Deficiency | 67,449.18 | |||
| Section 6166(a)(2) ratio - maximum amount of tax payable in installments | 74.1835% | |||
| Maximum amount of the deficiency that is payable in installments | 50,036.16 | |||
| Reconciliation | ||||
| Portion of the originally assessed tax that is not eligible for a §6166(h) election | 85,524.24 | |||
| Portion of the deficiency that is eligible for a §6166(h) election | 50,036.16 | |||
| The maximum amount of tax that could have been deferred under §6166 (rounded down to the amount stated in the PLR) | 135,560.36 | |||
| IRS's Calculation of the Annual Installment | ||||
| Total tax deferred under section 6166 | 50,036.16 | |||
| Number of installments elected | 10 | |||
| Annual Installment | 5,003.62 | |||
| IRS's Calculation of the Annual Installments Payable Under the §6166(h) Election | ||||
| Installment Number | Date | Prepayment Credit Available | Annual Installment Due | Annual Installment Payable |
| 1 | Feb-17-1986 | 0.00 | 5,003.62 | 5,003.62 |
| 2 | Feb-17-1987 | 0.00 | 5,003.61 | 5,003.61 |
| 3 | Feb-17-1988 | 0.00 | 5,003.62 | 5,003.62 |
| 4 | Feb-17-1989 | 0.00 | 5,003.61 | 5,003.61 |
| 5 | Feb-17-1990 | 0.00 | 5,003.62 | 5,003.62 |
| 6 | Feb-17-1991 | 0.00 | 5,003.61 | 5,003.61 |
| 7 | Feb-17-1992 | 0.00 | 5,003.62 | 5,003.62 |
| 8 | Feb-17-1993 | 0.00 | 5,003.61 | 5,003.61 |
| 9 | Feb-17-1994 | 0.00 | 5,003.62 | 5,003.62 |
| 10 | Feb-17-1995 | 0.00 | 5,003.62 | 5,003.62 |
| Total payments | 50,036.16 | 50,036.16 | ||