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This page contains a single entry by Associate Editor published on March 29, 2009 6:49 PM.

IRS Concludes Estate Tax Deficiency Attributable to Closely Held Business May Be Paid in Installments was the previous entry in this blog.

IRS Provides Guidance Re Addition to Tax Penalties is the next entry in this blog.

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IRS Determines Maximum Value of Collateral Required for Section 6324A Lien

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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.

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