...6166 election was defective. Section 6166 authorizes the installment election only if a major part of the estate consists of an "interest in a closely held business." The letter accompanying the return states that "the major asset of the estate consists of basically...

...and taxes of the decedent's estate, and restricting the availability to situations in which a large portion of the estate consists of an interest in a closely held business or businesses. Explanation of provisions In general. — The Act makes four changes in prior law. First,...

...6166 election was defective. Section 6166 authorizes the installment election only if a major part of the estate consists of an "interest in a closely held business." The letter accompanying the return states that "the major asset of the estate consists of basically...

...enacted in 1976, Congress believed that "additional relief should be provided to estates with illiquidity problems arising because a substantial portion of...a closely held business or other illiquid assets." S. Rep. 94-938, 94th Cong., 2d Sess. 18 (1976). The special use valuation and the section 6166 deferral...