IRS Issues Private Letter Ruling Granting Extension for Portability Election

March 2, 2026, 3:54 PM UTC

The IRS has 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 an estate not required to file a return under §6018, allowing the surviving spouse to claim the deceased spousal unused exclusion (DSUE) amount. [PLR 202609001]

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