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Get Revenue Procedure 2005-33 - Guidance On Exhausting Administrative Remedies Prior To Seeking A

Seeking a declaratory judgment pursuant to section 7479 of the Internal Revenue Code. A declaratory judgment may be requested from the United States Tax Court when an executor has made an election under section 6166 to extend the time for payment of estate tax with respect to an interest in a closely held business, and the Internal Revenue Service has (1) made a determination that the election cannot be made with respect to the estate or with respect to any property included therein, (2) failed.

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