PLR 201103016: Extension of time to make GST election

In PLR 201103016, the IRS ruled that when the taxpayer hired a CPA firm to prepare the 709 GST tax return and the CPA firm "failed to allocate Donor's available GST exemption" to the trust that the taxpayer had acted reasonably and had relied on advice from qualified tax professionals.   As such, the IRS permitted the taxpayer an additional 120 days to make the GST allocation.

See also PLR 201103039, for a very similar IRS ruling.

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