Ellie owned five apartment buildings, each worth $200,000. For three of the buildings, she worked with employees to keep the property in good repair.

This entailed maintaining electrical and plumbing fixtures, common areas, and walls and roofs, and providing janitorial services such as garbage removal, vacuuming, and rest room supplies. For the other two buildings, Ellie’s lease required the tenants to perform this work. Can her estate claim a § 6166 estate tax deferral for any of the buildings?