PROBATE & PROPERTY JULY/AUGUST 2008 9 Congress created section 6166 of the Internal Revenue Code to allow estates to pay the federal estate tax in installments. This benefit is available only to estates that own an interest in a closely held business. Congressional intent was to preserve the family business. Absent Code § 6166, an estate might be forced to sell the closely held family business to pay estate taxes. A key element of Code § 6166 is security. How does the IRS protect its interest in...