IRS Issues PLR Granting Extension for Portability Election of Deceased Spousal Unused Exclusion

March 23, 2026, 4:27 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 that allows a surviving spouse to utilize the deceased spouse’s unused exclusion (DSUE) amount where the estate was not required to file Form 706 under §6018(a). [PLR 202612006]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.

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