ESTATE OF

928 F.2d 901 91-1 USTC P 60,065 ESTATE OF Laura V. BELL, Deceased, Laurel V. Bell-Cahill, Executrix, Estate of Charles C. Bell, Deceased, Laurel V. Bell, Executrix, Petitioners-Appellants, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 89-70386. United States Court of Appeals, Ninth Circuit. Argued and Submitted Dec. 13, 1990. Decided March 25, 1991. John Gigounas, Simpson & Gigounas, San Francisco, Cal., for petitioners-appellants. Robert W. Metzler, Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee. On Appeal From a Decision of the United States Tax Court. Before HUG, BEEZER and BRUNETTI, Circuit Judges. BEEZER, Circuit Judge: 1 The Tax Court held that the crediting of overpayments made by a taxpayer who has elected to pay estate taxes in installments pursuant to 26 U.S.C. Sec. 6166 is governed by 26 U.S.C. Sec. 6403 . The Executrix appeals on the ground that the tax deferring benefits of section 6166 can be lost only under certain provisions within that section and thus section 6166 bars application of section 6403. We affirm. 2 * Laura V. Larsen Bell and Charles C. Bell died in February and April 1982. Laurel V. Bell-Cahill…