# 6166(b)(2)(C) Example 1

 Section 6166(b)(2)(C)  - Example 1 (Based on PLR 200006034) This example is based on PLR 200006034. The only mathematical information given in the PLR is that the value of the real estate with building was "approximately 44% of the value of the automotive parts business." The automotive parts business was a single business entity composed of the real estate with building and the operating Corporation. The figures in this example are hypothetical and are based on a 2016 date of death.

 Section 6166(b)(2)(C)  - Example 1 (Based on PLR 200006034)  Closely Held Business Assets Owned by the Grantor Trust on Date of Death Land and building - value is "approximately 44%" of the total business value (43.95% here) 6,680,000.00 100% of the Corporate stock value 8,520,000.00 Total closely held business value owned by the Grantor Trust 15,200,000.00

 Section 6166(b)(2)(C)  - Example 1 (Based on PLR 200006034)  Closely Held Business Assets Indirectly Owned by Decedent on Date of Death Land and building - assets used in Decedent's active trade or business as a sole proprietor under § 6166(b)(1)(A) 6,680,000.00 Decedent's stock in a corporation carrying on a trade or business under § 6166(b)(1)(C) 8,520,000.00 Total closely held business value included in Decedent's gross estate 15,200,000.00 §6166(b)(6) Adjusted Gross Estate Computation Gross estate 40,000,000.00 Allowable §2053 and §2054 deductions 3,180,000.00 Section 6166(b)(6) adjusted gross estate 36,820,000.00 §6166(a)(2) Ratio Computation Section 6166 business value 15,200,000.00 Section 6166(b)(6) adjusted gross estate 36,820,000.00 Section 6166(a)(2) ratio - maximum amount of tax which may be paid in installments 0.412819

 Section 6166(b)(2)(C)  - Example 1 (Based on PLR 200006034)  Hypothetical Estate Tax Computation 1 Gross estate 40,000,000.00 Schedules J, K, and L deductions 3,180,000.00 Marital deduction 0.00 Charitable deduction 2,500,000.00 2 Total allowable deductions 5,680,000.00 3a Tentative taxable estate 34,320,000.00 3b State death tax deduction 4,958,000.00 3c Taxable estate 29,362,000.00 4 Adjusted taxable gifts 0.00 5 Add lines 3c and 4 29,362,000.00 6 Tentative tax on the line 5 amount 11,690,600.00 7 Total gift tax paid or payable 0.00 8 Gross estate tax 11,690,600.00 9a Basic exclusion amount 5,450,000.00 9b DSUE amount 0.00 9c Applicable exclusion amount 5,450,000.00 9d Applicable credit amount 2,125,800.00 10 Adjustment to applicable credit amount 0.00 11 Allowable applicable credit amount 2,125,800.00 12 Subtract line 11 from line 8 9,564,800.00 13 Credit for foreign death taxes 0.00 14 Credit for tax on prior transfers 0.00 15 Total credits 0.00 16 Net estate tax 9,564,800.00 17 Generation-Skipping taxes payable 0.00 18 Total transfer taxes 9,564,800.00 Maximum Amount of Tax Which May be Paid in Installments Net estate tax 9,564,800.00 Section 6166(a)(2) ratio - maximum amount of tax which may be paid in installments 0.412819 Maximum amount of tax which may be paid in installments 3,948,531.17 Tax not deferred under § 6166 and payable on the return due date 5,616,268.83