According to e-mailed advice from the IRS, the maximum value of collateral the IRS may require as security for a section 6324A lien always includes any interest anticipated over the first four years of deferral. In addition, it is legally permissible if using a flat 2% rate results in an amount that is less than or equal to 45% of the underpayment interest rate.
Posted by Min Young Choi, Associate Editor, Wealth Strategies Journal.
Posted by Min Young Choi, Associate Editor, Wealth Strategies Journal.

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