All of the following statements about the ability to pay estate taxes attributable to closely held businesses over an installment period are correct except [see Code Sections 66010) and 6166(a)(3)].

A.The interest rate on the first $1 million (adjusted for inflation each year) of the taxable portion of the estate comprised of the closely held business is 2%.

B.The interest rate on any remaining portion of the estate tax attributable to a closely held business is 45% of the applicable rate for underpayments of tax.

C.The interest payments are deductible on the estate tax return.

D.Principal payments are not required under the installment plan until the fifth year.