www.section6166.com
Last Updated on Wednesday, 04 January 2012 19:24
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IRC SECTION 6166 INTERRELATED ESTATE TAX COMPUTATIONS
AND
BIFURCATION OF TAX DEFERRED UNDER SECTION 6166
Introduction
This site deals with a narrow area of the law regarding Federal estate taxes. One should be familiar with the basic provisions of Federal estate tax law and Internal Revenue Code (IRC) section 6166 to benefit from the materials on this site. See IRC sections 2001 et seq.; section 6166; section 6324A; section 6601(j); and the regulations related to those Code sections.
The materials illustrate the distinctions among the four types of section 6166 deferral computations and the mechanics of such computations. There are some notes about bifurcation of the tax deferred under section 6166. A progressive series of computations under the four types of 6166 deferrals shows the consequences of underpayments or overpayments of non-deferred tax resulting from differences in the 6166 election statement language. The nuances in IRS examination deficiency computations in 6166 deferral cases are explored. Interrelated state 6166 computations are illustrated, as well as interrelated state non-6166 interest computations. A table shows how the 2% portion of tax deferred under sections 6166(a) and (b)(10) is computed.
Other materials clarify IRS procedures regarding section 6166 cases. The differences between Master File and Non Master File returns are explained, as are the general Cincinnati Campus estate tax return processing steps.
The law has been changed for estates of decedents dying in 2010 and later. The method of computing the 2% portion of tax deferred under section 6166 has also been changed, and these changes are reflected in the new table.
Copyright © 2010 - 2012 by Nelson M. Blakely. All rights reserved. Copyright is not claimed for original U.S. Government materials or for the Inter-Est computation program.
Disclaimer
The material presented here is for illustration purposes only. It does not constitute legal advice in any respect. Computation examples involving state tax and interest cannot be relied upon as expressions of any state’s law or procedure. No reader should act or refrain from acting on the basis of any information presented herein without seeking the advice of counsel in the relevant jurisdiction. The author and his associates expressly disclaim all liability in respect of any actions taken or not taken based on any content of this website or any related blog postings.
Circular 230 Disclosure:
To the extent that anything written on this site constitutes an opinion on one or more Federal tax issues, such opinion was not written to be used and cannot be used by any taxpayer for the purpose of avoiding penalties.