PLR 8846001 Computation Illustration 4 - The IRS calculation of the deferred portion of the deficiency and the annual installments payable

 

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