the definition of terms used in this clause, 
see subsection (g). 
‘‘(2) TIME FOR PAYMENT OF INTEREST.—If the 
time for payment of any amount of tax has been ex-
tended under this section— 
‘‘(A) INTEREST FOR PERIOD BEFORE DUE 
DATE OF FIRST INSTALLMENT.—Interest pay-
able under section 6601 on any unpaid portion 
of such amount attributable to the period before 
the due date for the first installment shall be 
paid annually. 
‘‘(B) INTEREST DURING INSTALLMENT PE-
RIOD.—Interest payable under section 6601 on 
any unpaid portion of such amount attributable 
to any period after such period shall be paid at 
the same time as, and as a part of, each install-
ment payment of the tax. 
‘‘(C) INTEREST IN THE CASE OF CERTAIN 
DEFICIENCIES.—In the case of a deficiency to 
which subsection (e)(3) applies for a taxable 
year which is assessed after the due date for 
the first installment for such year, interest at-
tributable to the period before such due date, 
and interest assigned under subparagraph (B) 
to any installment the date for payment of 
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ycherry on PROD1PC64 with BILLS
which has arrived on or before the date of the 
assessment of the deficiency, shall be paid upon 
notice and demand from the Secretary. 
‘‘(e) SPECIAL RULES.— 
‘‘(1) APPLICATION
OF
LIMITATION
TO
PART-
NERS AND S CORPORATION SHAREHOLDERS.— 
‘‘(A) IN GENERAL.—In applying this sec-
tion to a partnership which is an eligible small 
business— 
‘‘(i) the election under subsection (a) 
shall be made by the partnership, 
‘‘(ii) the amount referred to in sub-
section (b)(1) shall be the sum of each 
partner’s tax which is attributable to items 
of the partnership and assuming the high-
est marginal rate under section 1, and 
‘‘(iii) the partnership shall be treated 
as the taxpayer referred to in paragraphs 
(2) and (3) of subsection (b). 
‘‘(B) OVERALL LIMITATION ALSO APPLIED 
AT PARTNER LEVEL.—In the case of a partner 
in a partnership, the limitation under sub-
section (b)(3) shall be applied at the partner-
ship and partner levels. 
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‘‘(C) SIMILAR
RULES
FOR
S
CORPORA-
TIONS.—Rules similar to the rules of subpara-
graphs (A) and (B) shall apply to shareholders 
in an S corporation. 
‘‘(2) ACCELERATION OF PAYMENT IN CERTAIN 
CASES.— 
‘‘(A) IN GENERAL.—If— 
‘‘(i) the taxpayer ceases to meet the 
requirement of subsection (c)(1)(A), or 
‘‘(ii) there is an ownership change 
with respect to the taxpayer, 
then the extension of time for payment of tax 
provided in subsection (a) shall cease to apply, 
and the unpaid portion of the tax payable in in-
stallments shall be paid on or before the due 
date for filing the return of tax imposed by 
chapter 1 for the first taxable year following 
such cessation. 
‘‘(B) OWNERSHIP CHANGE.—For purposes 
of subparagraph, in the case of a corporation, 
the term ‘ownership change’ has the meaning 
given to such term by section 382. Rules simi-
lar to the rules applicable under the preceding 
sentence shall apply to a partnership. 
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‘‘(3) PRORATION OF DEFICIENCY TO INSTALL-
MENTS.—Rules similar to the rules of section 
6166(e) shall apply for purposes of this section. 
‘‘(f) GROW ACCOUNT.—For purposes of this sec-
tion— 
‘‘(1) IN GENERAL.—The term ‘GROW Account’ 
means a trust created or organized in the United 
States for the exclusive benefit of an eligible small 
business, but only if the written governing instru-
ment creating the trust meets the following require-
ments: 
‘‘(A) No contribution will be accepted for 
any taxable year in excess of the amount al-
lowed as a deferral under subsection (b) for 
such year. 
‘‘(B) The trustee is a bank (as defined in 
section 408(n)) or another person who dem-
onstrates to the satisfaction of the Secretary 
that the manner in which such person will ad-
minister the trust will be consistent with the re-
quirements of this section. 
‘‘(C) The assets of the trust consist en-
tirely of cash or of obligations which have ade-
quate stated interest (as defined in section 
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1274(c)(2)) and which pay such interest not 
less often than annually. 
‘‘(D) The assets of the trust will not be 
commingled with other property except in a 
common trust fund or common investment 
fund. 
‘‘(E) Amounts in the trust may be used 
only— 
‘‘(i) as security for a loan to the busi-
ness or for repayment of such loan, or 
‘‘(ii) to pay the installments under 
this section. 
‘‘(2) ACCOUNT TAXED AS GRANTOR TRUST.— 
The grantor of a GROW Account shall be treated 
for purposes of this title as the owner of such Ac-
count and shall be subject to tax thereon in accord-
ance with subpart E of part I of subchapter J of 
this chapter (relating to grantors and others treated 
as substantial owners). 
‘‘(3) TIME WHEN PAYMENTS DEEMED MADE.— 
For purposes of this section, a taxpayer shall be 
deemed to have made a payment to a GROW Ac-
count on the last day of a taxable year if such pay-
ment is made on account of such taxable year and 
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