Cash Renting After Death: A Problem for Installment Payment of Federal Estate Tax?

Abstract

<p>Ordinarily, land that is cash rented after death which is subject to an election to pay federal estate tax in installments is considered “distributed, sold, exchanged, or otherwise disposed of” and the deferred tax is accelerated if the value of assets involved (plus all previous distributions, sales or disposition of assets after death) equals 50 percent or more of the date-of-death value of the interest in a closely-held business which qualified for installment payment. However, a recent private letter ruling has allowed cash renting of farmland after death without acceleration being triggered.</p>