PLR 201103003: Extension of time to elect alternative valuation for estate

In PLR 201103003, the IRS ruled that when the taxpayer hired an accountant to prepare the 706 estate tax return and the accountant filed the 706 "without regard to the alternate valuation election" that the taxpayer had complied with the requirements of sections 301-9100-1 and 301.9100-3 by "reasonably relied on a qualified tax professional, including a tax professional employed by the taxpayer, and the tax professional failed to make, or advise the taxpayer to make, the election."  As such, the IRS permitted the taxpayer an additional 120 days to make the alternative valuation election.

Posted by Joseph Siegmann, Associate Editor, Wealth Strategies Journal.