90 STAT. 1864
26 USC 2053, 2054. Ante, p. 1846.
PUBLIC LAW 94-455—OCT. 4, 1976 the interest in a closely held business which qualifies under subsection (a)(1). " (6) ADJUSTED GROSS ESTATE.—For purposes of this section, the term, 'adjusted gross estate' means the value of the gross estate reduced by the sum of the amounts allowable as a deduction under section 2053 or 2054. Such sum shall be determined on the basis of the facts and circumstances in existence on the date (including extensions) for filing the r e t u r n of tax imposed by section 2001 (or, if earlier, the date on which such r e t u r n is filed). "(c)
SPECIAL RULE FOR INTERESTS I N 2 OR MORE CLOSELY H E L D
BUSINESSES.—For purposes of this section, interests in 2 or more closely held businesses, with respect to each of which there is included in determining the value of the decedent's gross estate more than 20 percent of the total value of each such business, shall be treated as an interest in a single closely held business. For purposes of the 20-percent requirement of the preceding sentence, an interest in a closely held business which represents the surviving spouse's interest in property held by the decedent and the surviving spouse as community property or as joint tenants, tenants by the entirety, or tenants in common shall be treated as having been included in determining the value of the decedent's gross estate. " (d) ELECTION.—Any election under subsection (a) shall be made not later than the time prescribed by section 6075(a) for filing the r e t u r n of tax imposed by section 2001 (including extensions thereof), and shall be made in such manner as the Secretary shall by regulations prescribe. I f an election under subsection (a) is made, the provisions of this subtitle shall apply as though the Secretary were extending the time for payment of the tax. " (e) PRORATION OF D E F I C I E N C Y TO INSTALLMENTS. — I f an election is
made under subsection (a) to p a y any part of the tax imposed by section 2001 in installments and a deficiency has been assessed, the deficiency shall (subject to the limitation provided by subsection (a) (2)) be prorated to the installments payable under subsection (a). The part of the deficiency so prorated to any installment the date for payment of which has not arrived shall be collected a t the same time as, and as a part of, such installment. The part of the deficiency so prorated to any installment the date for payment of which has arrived shall be paid upon notice and demand from the Secretary. T h i s subsection shall not apply if the deficiency is due to negligence, to intentional disregard of rules and regulations, o r to fraud with intent to evade tax. "(f)
T I M E FOR P A Y M E N T OF I N T E R E S T. — I f the time for payment of
any amount of tax has been extended under this section— " (1) INTEREST FOR FIRST 5 YEARS.—Interest payable under section 6601 of any unpaid portion of such amount attributable to the first 5 years after the date prescribed by section 6151(a) for payment of the tax shall be paid annually. "(2)
INTEREST FOR PERIODS AFTER FIRST S YEARS.—Interest p a y -
able under section 6601 on any unpaid portion of such amount attributable to any period after the 5-year period referred to in paragraph (1) shall be paid annually a t the same time as, and as a part of, each installment payment of the tax. "(3)
INTEREST I N THE CASE o r CERTAIN DEFICIENCIES.—In the
case of a deficiency to which subsection (e) applies which is assessed after the close of the 5-year period referred to in paragraph (1), interest attributable to such 5-year period, and interest
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