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Installment Payments Permitted
In an attempt to maintain farming operations and limit liabilities during the administration of an estate, the estate distributed excess capital and converted sole proprietorship assets and a closely held C corporation into a newly formed limited liability company (LLC). The estate also transferred a portion of farmland to the estate of Decedent's daughter. These actions did not constitute a disposal of the
closely held business, and therefore did not prevent the estate from paying estate tax in installments under §6166(g). Excess capital was not part of the closely held business. Changing the form of business to an LLC was not a material alteration of the business. And assets transferred to the estate of Decedent's daughter were then leased to the LLC and remained part of the farming operation.
Source: Let. Rul. 200043031
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