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15 months after the date of decedent's death. See sec. 6075(a)
(estate tax return due 9 months after date of death); sec.
6081(a) (the Secretary may grant a reasonable extension of time
for filing any return; such extension not to exceed 6 months,
except in the case of taxpayers who are abroad); sec. 20.6081-
1(a), Estate Tax Regs. ("unless the executor is abroad, the due
date for filing the return under any extension granted by a
district director or a director of a service center may not be
later than 15 months * * * from the date of the decedent's
death"). The estate tax return was filed on January 19, 1996--
more than 33 months after the date of decedent's death and more
than 18 months after the extended due date to file the return.
Before the Deficit Reduction Act of 1984 (DEFRA), Pub. L.
98-369, 98 Stat. 494, the election to use the alternate valuation
date had to be exercised on a timely filed estate tax return
(including extensions), or it was lost.10 See, e.g., Estate of
Bradley v. Commissioner, 511 F.2d 527 (6th Cir. 1975), affg. T.C.
Memo. 1974-17; Estate of Ryan v. Commissioner, 62 T.C. 4, 10
(1974); Estate of Downe v. Commissioner, 2 T.C. 967, 970-971
(1943); Estate of Dixon v. Commissioner, T.C. Memo. 1990-17;
10Sec. 2032(c), 1954 I.R.C. (as amended), provided:
(c) Time of Election.--The election provided for
in this section shall be exercised by the executor on
his return if filed within the time prescribed by law
or before the expiration of any extension of time
granted pursuant to law for the filing of the return.
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