After his wife died on 1/8/18, her husband executor did not file Form 706 since his and his wife’s combined estates totalled far less than the estate exclusion amount of over $11,000,000. of either of them.
Now he is concerned that the estate exclusion amount could be decreased to $3,500,000. in the coming year and he wonders if there is any way to use portability of his deceased wife’s unused exemption (DSUE).
Presumably he should have filed Form 706 within 9 months or at least by 1/8/20 since there does appear to also be a 2-year window to file, so with the latter he would still need a 12-month extension since a 6-month extension would not suffice.
Is there any point in filing Form 4768 or does the IRS always limit an extension of the filing time to 6 months regardless of circumstances?
If a longer time might be granted, what kinds of good and sufficient causes other than severe illness or being out of the country would be accepted as making it impossible or impractical to file the Form 706 by the due date and why a previous request for automatic extension was not timely made?
Thank you for any help you can provide.