Wills, Trusts & Estates Prof Blog

Editor: Gerry W. Beyer
Texas Tech Univ. School of Law

Tuesday, January 28, 2014

IRS Provides for Automatic Extension for Portability Election


The IRS recently issued Rev. Proc. 2014-18, which provides for a simplified method for estates to obtain an automatic extension to make a portability election.  This late election relief is limited to estates for which the decedent died between December 31, 2010, and December 31, 2013. 

Taxpayers not eligible for relief under Rev. Proc. 2014-18 may receive an extension by requesting a private letter ruling under Reg. sec. 301.9100-3.

See Rev. Proc. 2014-18 – Automatic Extension Procedure for Making Portability Election Under Section 2010(c)(5), KPMG, Jan. 27, 2014.

Special thanks to Joel Dobris (Professor of Law, UC Davis School of Law) for bringing this article to my attention.


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