Section 6166(b)(4) provides:
For purposes of this section, value shall be value determined for purposes of chapter 11 (relating to estate tax).
|6166(b)(4) Comment 1: For purposes of §6166, the value for estate tax purposes is determined as of the date of death pursuant to §2031(a) and reflects all applicable valuation discounts that have been taken.|
|6166(b)(4) Comment 2: The value determined for estate tax purposes is also the value determined under §2032 alternate valuation or the §2032A special use valuation of certain farm or other real estate. The §2032A(c) additional estate tax payable in the event of a disposition of any interest in qualified real property or cessation of the qualified use of the qualified real property is not eligible for payment in installments under §6166; only the tax imposed by §2001 is eligible under §6166(a)(1). Section 2032A(c)(5) also provides that the qualified heir is personally liable for payment of the additional estate tax.|