All of the following statements concerning a Section 6166 installment payment of estate taxes attributable to the inclusion of a closely held business in a decedent's gross estate are correct except:

A) The business must constitute more than 35 percent of the decedent's adjusted gross estate.

B) The estate's personal representative has the sole discretion to elect a deferral of the estate tax payments.

C) If the estate qualifies, both the tax payments attributable to the business and the payments of interest on the unpaid balance must be paid in equal installments for 15 years.

D) Under certain circumstances the estate will forfeit its right to the installment payments and the remaining unpaid tax will be accelerated for payment.