All of the following statements concerning a Section 6166 instalment payment of estate taxes attributable to the inclusion of a closely held business in a decedent’s gross estate are correct EXCEPT:
(A) Under certain circumstances, the estate will forfeit its right to the instalment payments and the remaining unpaid tax will be accelerated for payment.
(B) The business must constitute more than 35% of the decedent’s adjusted gross estate.
(C) If the estates qualify, both the tax payments attributable to the business and the payments of interest on the unpaid balance must be paid in equal instalments for 15 years.
(D) The estate’s personal representative has the sole discretion to elect a deferral of the estate tax payments.
Provide a detailed explanation for your answer. Only answer if you have a strong estate planning background.