Problems of 6166

Deferred payment is available only on business/farm assets. The IRS must be convinced there is sufficient reason why taxes cannot be paid on time.
Difficult to plan for use of 6166: The estate may cease to qualify if non-business assets appreciate faster than business assets or the value of the business declines.
The IRS can place a lien on the business. This frees the executor of responsibility but can impair the business, its public image, and the heirs.
The interest charged is based upon the IRS rate for deficiencies. The executor has the responsibility to pay the taxes, but this liability can impair the business, its public image, and the heirs.
Full amount of deferral becomes due if:

a) A payment is late or missed

b) 50% or more of the assets from the business are withdrawn

c) 50% or more of the value of the business interest is sold, exchanged, or distributed to anyone other than a beneficiary designated in the Will as entitled to receive the interest