SECTION 1. PURPOSE

This notice grants to qualifying estates, for the purpose of electing under section 2010(c)(5)(A) of the Internal Revenue Code (Code) (a “portability election”), a six-month extension of time for filing Form 706 (United States Estate (and Gen- eration-Skipping Transfer) Tax Return) . This extension applies when the executor of a qualifying estate did not file a Form 4768 (Application for Extension of Time To File a Return and/or Pay U.S. Estate (and Generation-Skipping Trans- fer) Taxes) within nine months after the decedent’s date of death, and therefore the estate did not receive the benefit of the automatic six-month extension. An executor of a qualifying estate that wants to obtain the extension granted by this notice must file the application for a six-month extension no later than 15 months after the decedent’s date of death. With the extension granted by this notice, the Form 706 of a qualifying estate will be due 15 months after the decedent’s date of death.

Generally, this notice defines a qualifying estate as the estate of a decedent (1) whose date of death is after December 31,

2010, and before July 1, 2011, (2) who is survived by a spouse, and (3) whose gross estate does not exceed the $5,000,000 basic exclusion amount for 2011. The extension provided in this notice is granted pursuant to authority under section 6081 of the Code.