Priv. Ltr. Rul. 200909044 (Dec. 2, 2008)

(maximum value of required property under I.R.C. § 6324A includes the amount of interest expected to become payable over first four years of deferral; if use of flat 2 percent interest rate results in amount that is less than or equal to 45 percent of underpayment interest rate, it is legally permissible).