873 / Can the time for paying the estate tax be extended if the estate includes a reversionary or remainder interest?

If the gross estate includes a reversionary or remainder interest, the executor may elect to postpone payment of the portion of the tax attributable to that interest until six months after termination of the precedent interest in the property. Notice of the election to exercise postponement, together with supporting documents and information, must be filed with the district director before the due date for payment of the tax. The IRS may, for “reasonable cause,” extend payment of the tax postponed because of the reversionary or remainder interest for up to an additional three years beyond the postponement period referred to above.¹