Page:United States Statutes at Large Volume 98 Part 1.djvu/941

 PUBLIC LAW 98-369—JULY 18, 1984

98 STAT. 893

"(B) the tax imposed by section 2001 with respect to such taxable estate reduced by the sum of the credits allowable against such tax. "(c) INSTALLMENT PAYMENTS.— "(1) IN GENERAL.—If^

"(A) the executor of the estate of the decedent (without regard to this section) elects to have the provisions of section 6166 (relating to extensions of time for payment of estate tax where estate consists largely of interest in closely ^,. held business) apply to payment of that portion of the tax imposed by section 2001 with respect to such estate which is attributable to employer securities, and "(B) the plan administrator or the cooperative provides to the executor the agreement described in subsection (e)(D, then the plan administrator or the cooperative may elect, before the due date (including extensions) for filing the return of such tax, to pay all or part of the tax described in subsection (b)(2) in installments under the provisions of section 6166. "(2) INTEREST ON INSTALLMENTS.—In determining the 4-percent portion for purposes of section 6601(j)— "(A) the portion of the tax imposed by section 2001 with respect to an estate for which the executor is liable, and "(B) the portion of such tax for which an employee stock ownership plan or an eligible worker-owned cooperative is liable, shall be aggregated.

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"(d) GUARANTEE OF PAYMENTS.—Any employer—

"(1) whose employees are covered by an employee stock ownership plan, and "(2) who has entered into an agreement described in subsection (e)(2) which is in effect, shall guarantee (in such manner as the Secretary may prescibe) the payment of any amount such plan is required to pay under subsection (b), including any interest payable under section 6601 which is attributable to such amount. "(e) AGREEMENTS.—The agreements described in this subsection are as follows: "(1) A written agreement signed by the plan administrator, or by any authorized officer of the eligible worker-owned cooperative, consenting to the application of subsection (b) to such plan or cooperative. "(2) A written agreement signed by the employer whose employees are covered by the plan described in subsection (b) consenting to the application of subsection (d). "(f)

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EXEMPTION FROM TAX ON PROHIBITED TRANSACTIONS.—The

assumption under this section by an employee stock ownership plan of any portion of the liability for the tax imposed by section 2001 shall be treated as a loan described in section 4975(d)(3). "(g) DEFINITIONS.—For purposes of this section— "(1) EMPLOYER SECURITIES.—The term 'employer securities' has the meaning given such term by section 409(1). Ante, p. 852. "(2) EMPLOYEE STOCK OWNERSHIP PLAN.—The term 'employee stock ownership plan' has the meaning given such term by section 4975(e)(7). "(3) EuGiBLE WORKER-OWNED COOPERATIVE.—The term 'eligible worker-owned cooperative' has the meaning given to such term by section 1041(b)(2). Ante, p. 793.

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