Priv. Ltr. Rul. 201217012 (Jan. 13, 2012)

(IRS allowed late allocation of GSTT exemption to lifetime transfer to irrevocable trust; trust created and funded before rule allowing for automatic allocation of any unused GSTT exemption to indirect skips; gift tax return did not allocate any GSTT exemption which wasn't discovered until after transferor's death; at time of ruling request, no taxable distributions or terminations had taken place; IRS proposed regulations in 2008 establishing more rigorous documentation requirements for return preparers and advisors, not yet finalized).