| Section 6166 Practice Notes | |
| 1 | Administration expenses that are allowable as deductions on Form 706 but which are claimed on the estate 1041 must be included in the §6166(b)(6) adjusted gross estate computation. |
| 2 | The section 2058 state death tax deduction is by definition not included in the §6166(b)(6) adjusted gross estate computation. |
| 3 | Many estates with §6166 elections file their returns on the extended due date 15 months after date of death pursuant to section 6081. If an IRS examination increases the amount of tax not deferred under section 6166, there will be a deduction for interest accrued on Federal estate tax as of the filing date in the 6166(b)(6) adjusted gross estate computation. Interest accrued on any unpaid state death tax on the filing date is also includible in the computation. |
| 4 | Cincinnati Campus will often include the full amount of Schedules J, K, and L deductions in their §6166(b)(6) adjusted gross estate computation notwithstanding any contrary adjustments that an estate might have made in its computation in its notice of election. |
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