SECTION 4. RELIEF FOR

CERTAIN LATE PORTABILITY ELECTIONS

.01 Procedural Requirements for Re- lief . The requirements for relief under this revenue procedure are as follows:

(1) A person permitted to make the election on behalf of a decedent, pursuant to § 20.2010–2T(a)(6), must file a complete and properly-prepared Form 706 on or before December 31, 2014. The Form 706 will be considered complete and properly prepared if it is prepared in accordance with § 20.2010–2T(a)(7).

(2) The person filing the Form 706 on behalf of the decedent’s estate must state at the top of the Form 706 that the return is “FILED PURSUANT TO REV. PROC. 2014–18 TO ELECT PORTABILITY UNDER § 2010(c)(5)(A).”

February 10, 2014 514 Bulletin No. 2014–7

.02 Extent of Relief . If it is determined that the requirements for granting relief, as provided in sections 3.01 and 4.01 of this revenue procedure, have been satisfied, the taxpayer will be deemed to meet the requirements for relief under § 301.9100–3 and relief is granted under the provisions of § 301.9100–3 to extend the time to elect portability under § 2010(c)(5)(A). Accordingly, for purposes of electing portability, the taxpayer’s Form 706 will be considered to have been timely filed in accordance with § 20.2010–2T(a)(1). The taxpayer will receive an estate tax closing letter acknowledging receipt of the taxpayer’s Form 706.

.03 Subsequent Determination that Taxpayer Is Required to File a Return under § 6018(a) . If, subsequent to the grant of relief pursuant to this revenue procedure, it is determined that, based on the value of the gross estate and taking into account any taxable gifts, the taxpayer was required to file an estate tax return pursuant to § 6018(a), the grant of an extension referred to in section 4.02 of this revenue procedure is deemed null and void upon such a determination.