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Revocations and Rejections

Tuesday, December 1, 2015

Among this week's release of private letter rulings were three rejection letters, PLRs 201548020, 201548021, and 201548025, the latter sustained on appeal; and one revocation, PLR 201548024, also sustained on appeal.

PLR 201548004 - Late Portability Election

Monday, November 30, 2015

In PLR 201548004, the Service granted a discretionary extension to the executor of a decedent's estate to allocate a deceased spouse's unused exemption amount to the surviving spouse.

PLR 201548012 - Late Section 754 Election

Monday, November 30, 2015

In PLR 201548012, the Service exercised its discretion to allow a late election to adjust the inside basis of a decedent's interest in a general partnership.

Consolidated Estate and Tax Planning Update

Monday, November 30, 2015

At times, IRS issues rulings that are important to some charitable planners who also work in the estate planning and related tax planning fields. For those individuals, we include in this current event a listing to consolidate several rulings of potential interest. More information about these consolidated rulings, including the text, summary, extended summary, and commentary (as the case may be), is available for review through the links.

Two PLRs Allow Late Election Out of Automatic GST Exemption Allocation

Monday, November 30, 2015

In two identical rulings, PLRs 201548001 and 201548002, the Service exercised its discretion to allow a couple belatedly to elect out of the automatic allocation of GST exemption to transfers to an irrevocable life insurance trust with skip potential.

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