Stewart told the Yorkshire Post: "I think we will lose points at the start of next season, whatever happens, and I have been advised that both legally and financially, this is the right step to take.
"I am not a Roman Abramovich and I am a novice in the football market - but I am an experienced businessman who wants this club to go places."
With the Inland Revenue owned a substantial amount of money and being the Millers' major creditors, it's unlikely they would agree to any repayment method, be it a penny in the pound or otherwise. Therefore Stewart is set to acquire the club under a new company name.
Stewart continued: "When you look at what has gone before, this club has been relying on fanatical fans who had the right intentions. But you have got to be more pragmatic and if expenditure is greater than income, you are going to be in trouble.
"I would not have signed the lease for the ground and that has now become a big problem. Negotiations with the Booth family are ongoing but so far they have been quite negative."
Ex-chairman but still current ground owner Booth currently receives around £16,000 a month, the breakdown includes about 4.5k for Millmoor, 2.5k for the Rotherham United Suite and around 500-1k for Hooton Lodge.
The rest is made up of repayments of around 600k from the Booths which kept the club going during their initial CVA from February 06 to the end of that season.
Elsewhere Leeds United will find out today if their 15 point appeal for exiting administration in the same fashion, a fate which Rotherham could well suffer come August, will be overturned.