Executor Loses Out on Fees Due to Section 6166 Lien
A personal representative/executor for an estate granted a special estate tax lien under Code §6324A to the U.S. as part of a Section 6166 election to defer payment of federal estate tax. At the time, the executor had been paid only been part of his fees, leaving $486,265 unpaid. The IRS has the ability to demand a lien before allowing a Section 6166 election if adequate bond is not posted.
During the course of the lien period, the value of the liened property fell below the amounts still due to the IRS . . .
U.S. v. Spoor, 118 AFTR 2d 2016-xxxx (11th Cir 10/4/16)