IRS Issues Private Letter Ruling Granting Extension for Estate to Elect Portability 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 for the decedent’s estate to file Form 706 and make a portability election, allowing the surviving spouse to utilize the deceased spousal unused exclusion (DSUE) amount where the estate was not required to file an estate tax return under §6018(a) based on the value of the gross estate. [PLR 202610011]

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