The IRS has published a private letter ruling on Section 2010 and Treasury Regulation Section 301.9100 granting an extension of time for a decedent’s estate to file Form 704 and make a portability election under Section 2010(c)(5)(A) to allow the decedent’s surviving spouse to take into account the decedent’s deceased spousal unused exclusion amount. [PLR 202341010]
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