Attorneys Seeking Relief for Filing of Estate Tax Portability

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Tax professionals are asking the IRS to drop the current requirement that “9100 relief” for late elections of estate tax portability require the submission of a private letter ruling. Richard Franklin of McArthur Franklin PLLC says he and another practitioner are writing a proposal to ask the government to create a six-month window in which all portability elections may be filed in a simple format without the need to file a private letter ruling request, and without having to pay a fee.