ESTATE TAX

T.D. 9172, page 468. Final regulations under section 2032 of the Code concern the election to value a decedent’s gross estate on the alternate valuation date. The final regulations reflect a change to the law made by the Deficit Reduction Act of 1984. As a result of the final regulations, section 301.9100–6T(b) of the regulations will be removed. Please note: the preamble of the final regulations describes a change in the IRS’s position on the availability of relief to make the section 2032 election or protective election, and the section 2056A(d) election under sections 301.9100–1 and 301.9100–3 of the regulations.