Priv. Ltr. Rul. 201217011 (Jan. 18, 2012)

(extension of time granted to divide testamentary QTIP trust and make reverse QTIP election with respect to a portion of the trust and allocate decedent's unused GSTT exemption to that particular portion; decedent's will created pecuniary marital QTIP for surviving spouse and residuary credit shelter trust for children and grandchildren; upon surviving spouse's death, balance in QTIP to be added to residuary trust and upon death of last of decedent's children, remaining amount to be distributed per stirpes to grandchildren and more remote descendants; scrivener failed to divide QTIP trust into GST exempt and non-exempt portions and did not make reverse QTIP election; at time of ruling request (after death of surviving spouse) trustee had made no taxable distributions or terminations).

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