The following is part of the estate tax calculation for one of your clients who died in the current year:

ASSET VALUE

Black Aces Inc. $$6,200,000$

Remainder of estate $9,500,000$

Total gross estate $$15,700,000$

Funeral and administrative expenses $($$$60,000)$

Debts of decedent $(40,000)$

Total Deductions for AGE $($$$100,000)$

Adjusted gross estate $$15,600,000$

Marital deduction $($$$-0-)$

Charitable deduction $(200,000)$

Taxable estate $$15,400,000$

Your client solely owned and personally operated Black Aces Inc. for the last $25$ years of his life. His will leaves the business outright to his son, $$200,000$ to charity, and the remainder to his daughter.

Is the estate entitled to apply to pay estate taxes on the farm property in installments under IRC Section $6166,$ and why or why not?

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