IRS Issues PLR Granting Estate Extension to Elect Portability of Deceased Spousal Unused Exclusion Amount

March 16, 2026, 3:15 PM UTC

The IRS issued a private letter ruling on I.R.C. §2010 and Treas. Reg. §301.9100 granting decedent’s estate a 120-day extension to make a portability election allowing the surviving spouse to take into account the deceased spousal unused exclusion (DSUE) amount when the estate was not required to file an estate tax return under §6018(a). [PLR 202611006]

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