ESTATE TAX

Notice 2011–82, page 516. This notice provides guidance under section 2010 of the Code on electing portability of a deceased spousal unused exclusion amount on a Form 706 (United States Estate (and Generation- Skipping Transfer) Tax Return) . This notice also announces that the Treasury Department and the Service intend to issue regulations to implement the provisions of section 2010(c) and invites public comments.

Rev. Proc. 2011–48, page 527. This procedure instructs taxpayers how to file a protective claim for refund when the estate has a claim or expense not yet deductible under section 2053 of the Code and the corresponding regulations. In addition, this procedure details the procedures the Service will follow in processing these protective claims for refund. Finally, this procedure instructs taxpayers how to notify the Service that a section 2053 protective claim for refund is ready for consideration.