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.
The latest form for Internal Revenue Code Section 6324A Lien Agreement Form expires 2023-12-31 and can be found here.
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