The enactment of “portability”1 in the Tax Relief Act of 20102 has met with widespread approval, particularly among those who tend to procrastinate in their estate planning efforts. For individuals (and couples) who simply did not get around to restructuring asset ownership after marriage or who harbored a deep reluctance to leave the other spouse with enough property to achieve a rational tax result over both deaths, the enactment seemed to be a good move.



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