A bill to amend the Internal Revenue Code of 1954 to provide a declaratory judgement with regard to the extension of time for payment of estate tax.

Amends the Internal Revenue Code to provide that the Tax Court, the U.S. Claims Court, or a U.S. district court may issue a declaratory judgment in a case brought by an executor involving the extent to which an estate is eligible for the extension of time for payment of the estate tax where the estate consists largely of an interest in a closely held business. Provides that such a judgment shall be a final judgment or decree and shall be reviewable.

Requires the exhaustion of all administrative remedies within the Internal Revenue Service before a judgment may be issued.

Prohibits the levy or proceeding in court for the collection of tax on an estate until final declaratory judgment is rendered.

Requires the filing of an appeals bond for an appeal of a declaratory judgment on the extension of time for payment of the estate tax. Allows the U.S. Court of Appeals and the Supreme Court to impose damages for frivolous or groundless appeals.

Imposes a negligence penalty on an estate for underpayment of tax where a court determines that such an estate does not qualify for an extension of time for payment of estate tax.