TCP Estate Tax · Updated November 2026
Section 6166 Estate Tax Installment Election: Why Closely Held Businesses Matter
The rule can reduce pressure to sell a family business immediately for liquidity.
Purpose
The election can allow qualifying tax attributable to a closely held business to be paid in installments.
Qualification
Eligibility depends on statutory ownership and estate-percentage requirements and other rules.
Planning effect
Installments can improve estate liquidity and reduce forced-sale pressure.
Exam strategy
Large closely held business plus estate liquidity problem should trigger Section 6166 analysis.
The takeaway
Section 6166 can spread qualifying estate-tax payments over time for certain closely held business estates.
Related Summit resources
FAQ
Is Section 6166 for every estate?
No.
Does it relate to closely held businesses?
Yes.
Can it spread payments over time?
Yes.