IRS Issues Private Letter Ruling Granting Extension for Portability Election of Deceased Spousal Unused Exclusion Amount

The IRS issued a private letter ruling on I.R.C. §2010 and Treas. Reg. §301.9100 granting a 120-day extension to make a portability election for deceased spousal unused exclusion (DSUE) amount where the estate was not required to file Form 706 under I.R.C. §6018(a) based on the value of the gross estate and taxable gifts. [PLR 202610007]

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