Under PL 94-455 and 26 U.S.C 6324A of the Internal Revenue Code, any estate with respect to which an election has been made under section 6166 and files the lien agreement, the deferred amount (plus any interest, additional amount, additional to tax, assessable penalty, and cost attributable to the deferred amount) shall be a lien in favor of the United States on the section 6166 lien property. The election under section 6324A will not be effective unless all parties having an interest in the property, subject to the lien, sign an agreement in which they consent to the creation of the lien. The election may be filed at any time prior to payment of the full amount of the estate tax and interest due.
US Code:
26 USC 6324A
Name of Law: Special liens for estate and gift taxes
US Code:
26 USC 6166
Name of Law: Extension of time for payment of estate tax where estate consists largely of interest in closely hel
PL:
Pub.L. 94 - 455 2004(d)(1)
Name of Law: Tax Reform Act of 1976
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.