It really doesn't matter for small taxpayers becuase there is no interest capitalization and other complications, but the logic would be same, wouldn't it? 

Hi Greg,If this were me, providing the money to pay the back taxes was in a bank account or could be borrowed (credit card tax payment, family loan, etc...)

Half of me says you are being taken advantage of, but I really suspect your friend just doesn’t know what he’s doing.I could go on about late fees, default interest, usury, lien position (which doesn’t exist), title and hazard insurance requirements, legal disclosures, personal guarantees, tax payments, etc.

It allows the taxpayer to structure tax payments over anytime, while the capital is put to work through real estate, private equity, stocks and bonds, or any other investment.

This is way before you start then figuring out how much of that is eligible for the 199A exclusion.Also, if you look at the instructions for the 3115, you'll note the following at the bottom:Time Per Response Recordkeeping ............... 60 hours, 1 minute Learning ................... 16 hours, 25 minutes Preparing .................. 20 hours Sending ................... 32 minutesWhile the IRS frequently overestimates the amount of time a mostly organized taxpayer takes to put together these forms, I think the above is actually not a horrible estimate for this particular form. 

Every form of energy is heavily subsidized to the tune of trillions of taxpayer dollars a year.

If borrowed funds are deposited into an account already containing other funds, the borrowed funds are presumed to be expended first.If borrowed funds from several loans are deposited into an account at different times, the funds from the earliest loan are presumed to be expended first (FIFO concept).If borrowed funds from several debts incurred at the same time are deposited into an account at the same time, the taxpayer can select the order in which the funds are presumed to be deposited into the account.If an expenditure from an account (or from cash not held in an account) is made within 30 days after the deposit (or receipt in cash) of borrowed funds, the taxpayer can treat the expenditure as made from the borrowed funds (to the extent of such borrowed funds).

This is a determination best made in conjunction with the taxpayer's financial and tax advisors.

A penny less than this and taxpayers are effectively subsidizing badly run businesses that should either change, become more efficient through automation, etc. or should fail.

Proc. 2008-16, the IRS will not challenge that a property qualifies for Section 1031 gain deferral if—1. the relinquished property has been held for at least 24 months immediately preceding the exchange and in each of the two 12-month periods immediately preceding the exchange,a. the taxpayer rents the residence to another person at fair market value for at least 14 days, andb. the taxpayer does not use the property more than the greater of 14 days or 10% of the total number of days the property was used; and2. the replacement property is held for at least 24 months immediately after the exchange and in each of the two 12-month periods immediately following the exchange,a. the taxpayer rents the residence to another person at fair market value for at least 14 days, andb. the taxpayer does not use the property more than the greater of 14 days or 10% of the total number of days the property was used.That’s a safe harbor.