Estate of Edward P. Roski, Sr., Edward P. Roski, Jr. v. Commissioner

128 T.C. No. 10

UNITED STATES TAX COURT ESTATE OF EDWARD P. ROSKI, SR., DECEASED, EDWARD P. ROSKI, JR., EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5639-05. Filed April 12, 2007. The estate elected to pay its tax in installments under sec. 6166(a)(1), I.R.C. (the election). R informed the estate that it would have to secure a bond equal to twice the amount of tax deferred or provide a special lien under sec. 6324A, I.R.C. (special lien), in order to qualify for the election. R’s requirement was based on a recent decision by R to make a bond or a special lien…