A decedent owned 25% of the voting stock of Siskin Corporation. Siskin has 53 shareholders. The decedent's estate cannot qualify for the § 6166 election.

Question

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The § 6166 election allows for the deferral of estate tax payments for closely held businesses if the decedent owned at least 20% of the voting stock or if the corporation has 45 or fewer shareholders. Since the decedent owned 25% of the voting stock, the estate can qualify for the election despite the number of shareholders.

A Decedent Owned 25% of the Voting Stock of Siskin