Here, the decedent's estate wanted to make an alternate valuation election pursuant to I.R.C. Sec. 2032. However, the estate didn't file the estate tax return within a year of the due date for the return. Thus, I.R.C. Sec. 2032(d)(2) was not satisfied and the estate was not eligible for an extension of time to file. Priv. Ltr. Rul. 201441001 (Jun. 6, 2014).