IRS PLR: Portability Election Extension Granted (IRC §2010)

The IRS has published a private letter ruling on Section 2010(c)(5)(A), granting the taxpayer’s estate an extension of 120 days to make the portability election to allow the decedent’s surviving spouse to take into account the decedent’s deceased spousal unused exclusion (DSUE) amount, by filing a complete and properly prepared Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, with the IRS. [PLR 202536001]

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