Priv. Ltr. Rul. 201403012 (Sept. 25, 2013)

(decedent owned general partnership interest with son that made up in excess of 50 percent of decedent's estate and estate's executor had elected installment payment of federal estate tax for estate; partnership assets consisted entirely of commercial real estate parcels titled in decedent's and son's names as tenants-in-common as nominee for partnership; executor proposed to distribute undivided interests in each parcel to partner's on pro-rata basis and then recontribute such interests to newly formed limited liability companies with each new LLC to hold a separate parcel; no other money or property involved in transaction; based on Rev. Rul. 66-62, IRS determined that transaction was mere change in form with no acceleration of installment payment of estate tax triggered; no mention of whether election itself was valid).