Assume, for this question only, that Kenny and Melissa were married today. They went straight to Kennys lawyers office to execute new wills and a QDOT trust document. On the way home from executing a valid will leaving all assets to Melissa, Kenny and Melissa were in a serious car accident. Kenny was comatose for several days before dying. His unpaid medical expenses were $150,000; Melissa had medical expenses for the accident of $10,000. The day after Kenny died, Melissa gave Kennys three children and three grandchildren each $22,000 then left for France to stay with her mother. Prior to Kenny's death, Kenny and Melissa gave Kenny's mother $60,000. Kennys estate may have some issues liquidating the portfolio to pay taxes; would his estate be eligible to use the installment payments under 6166?

A) Yes, this election would be available.

B) No, this election would not be available.