A decedent owned 25% of the voting stock of Siskin Corporation, which has 53 shareholders. The decedent's estate cannot elect the deferral of estate tax payments.

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The estate may still be eligible to elect the deferral of estate tax payments under IRC Section 6166, which allows for the deferral of estate tax attributable to a closely held business, provided other specific requirements are met, such as the decedent's interest in the closely held business exceeding 35% of their adjusted gross estate. The number of shareholders in the corporation does not directly disqualify the estate from this election.

A Decedent Owned 25% of the Voting Stock of Siskin