Loss of the Portability Election: Estate of Rowland v. Commissioner

Dec 16, 2025
9 mins

Episode Description

Portability can be a powerful tool—until it isn't. In this new ACTEC Trust and Estate Talk episode, we break down Estate of Rowland v. Commissioner and how an incomplete estate tax return cost the surviving spouse $3.7 million in DSUE. Learn what went wrong, why the relaxed reporting rules didn't apply, and the key steps practitioners should take to safeguard a valid portability election.

The American College of Trust and Estate Counsel, ACTEC, is a professional society of peer-elected trust and estate lawyers in the United States and around the globe. This series offers professionals best practice advice, insights, and commentary on subjects that affect the profession and clients. Learn more in this podcast.

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