90 STAT. 1868
26 USC 6161.
PUBLIC LAW 94-455—OCT. 4, 1976 for a reasonable period not in excess of 10 years from the date prescribed by section 6151(a) for payment of the tax (or, in the case of an amount referred to in subparagraph (B), if later, not beyond the date which is 12 months after the due date for the last installment)." (2) Subsection (b) of section 6161 (relating to extension of time for payment of certain deficiencies) is amended to read as follows: " (b) A M O U N T DETERMINED AS D E F I C I E N C Y. — " (1) I N C O M E, GIFT, AND CERTAIN OTHER TAXES.—Under regula-
26 USC 6163.
tions prescribed by the Secretary, the Secretary may extend the time for the payment of the amount determined as a deficiency of a tax imposed by chapter 1, 12, 41, 42, 43, o r 44 for a period not to exceed 18 months from the date fixed for the payment of the deficiency, and in exceptional cases, for a further period not to exceed 12 months. A n extension under this paragraph may be g r a n t e d only where it is shown to the satisfaction of the Secretary that payment of a deficiency upon the date fixed for the payment thereof will result in undue h a r d s h i p to the tax p a y e r in the case of a tax imposed by chapter 1, 41, 42, 43, or 44, or to the donor in the case of a tax imposed by chapter 12. " (2) ESTATE TAX,—Under regulations prescribed by the Secretary, the Secretary may, for reasonable cause, extend the time for the payment of any deficiency of a tax imposed by chapter 11 for a reasonable period not to exceed 4 years from the date otherwise fixed for the payment of the deficiency. " (3) No EXTENSION FOR CERTAIN DEFICIENCIES.—No extension shall be granted under this subsection for any deficiency if the deficiency is due to negligence, to intentional disregard of rules and regulations, or to fraud with intent to evade tax." (3) Subsection (b) of section 6163 (relating to extension to prevent undue h a r d s h i p in case of reversionary or remainder interest) is amended to read as follows: •'(b) EXTENSION FOR REASONABLE CAUSE.—At the e x p i r a t i o n of the
26 USC 6503.
period of postponement provided for in subsection (a), the Secretary may, for reasonable cause, extend the time for payment for a reasonable period or periods not in excess of 3 years from the expiration of the period of postponement provided in subsection (a), " (4) Subsection (d) of section 6503 (relating to extensions of time for payment of estate tax) is amended by striking out "section 6166" and inserting i n lieu thereof "section 6163, 6166, or 6166A". (d) SPECIAL L I E N FOR ESTATE T A X DEFERRED U N D E R SECTION 6166.—
26 USC 6324A.
(1) IN GENERAL.—Subchapter C of chapter 64 (relating to lien for taxes) is amended by inserting after section 6324 the following new section: «SEC. 6324A. SPECIAL LIEN FOR ESTATE TAX DEFERRED UNDER SECTION 6166 OR 6166A. " (a) GENERAL RULE. — I n the case of any estate with respect to which an election has been made under section 6166 or 6166A, if the executor makes an election under this section ( a t such time and in such manner as the Secretary shall by regulations prescribe) and files the agreement referred to in subsection (c), the deferred amount (plus any interest, additional amount, addition to tax, assessable penalty, and costs attributable to the deferred amount) shall be a lien in favor of the United States on the section 6166 lien property. " (b) SECTION 6166 L I E N PROPERTY.—
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