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date of death of the decedent whose DSUE is being figured, or (b) the decedent's applicable exclusion amount less the amount on line 5 of Part 2—Tax Computation on the Form 706 for the estate of the decedent. Amounts on which gift taxes were paid are excluded from adjusted taxable gifts for the purpose of this computation. When a surviving spouse applies the DSUE amount to a lifetime gift or bequest at death, the IRS may examine any return of a predeceased spouse whose executor elected portability to verify the allowable DSUE amount. The DSUE amount may be adjusted or eliminated as a result of the examination; however, the IRS may only make an assessment of additional tax on the return of the predeceased spouse within the applicable limitations period under section 6501. Special Rule Where Value of Certain Property Not Required To Be Reported on Form 706 The regulations provide that executors of estates who are not otherwise required to file Form 706 under section 6018(a) do not have to report the value of certain property qualifying for the marital or charitable deduction. For such property, the executor may estimate the value in good faith and with the due diligence to be afforded all assets includible in the gross estate. The amount reported on Form 706 will correspond to a range of dollar values and will be included in the value of the gross estate shown on line 1 of Part 2—Tax Computation. See the instructions for lines 10 and 23 of Part 5—Recapitulation, earlier, for more details. Specific Instructions Portability Election. If you intend to elect portability of the DSUE amount, timely filing a complete Form 706 is all that is required. Complete Section B if any assets of the estate are being transferred to a qualified domestic trust and complete Section C of this Part to figure the DSUE amount that will be transferred to the surviving spouse. Section A. Opting Out of Portability. If you are filing Form 706 and do not wish to elect portability, then check the box indicated. Do not complete Section B or C. Section B. Portability and Qualified Domestic Trusts (QDOTs). A QDOT allows the estate of a decedent to bequeath property to a surviving spouse who is not a citizen of the United States and still receive a marital deduction. When property passes to a QDOT, estate tax is imposed under section 2056A as distributions are made from the trust. When a QDOT is established and there is a DSUE amount, the executor of the decedent’s estate will determine a preliminary DSUE amount for the purpose of electing portability. This amount will decrease as section 2056A distributions are made. In estates with a QDOT, the DSUE amount generally may not be applied against tax arising from lifetime gifts because it will not be available to the surviving spouse until it is finally determined, usually upon the death of the surviving spouse or when the QDOT is terminated. Note. If a surviving spouse who is not a citizen of the United States becomes a citizen and the section 2056A tax no longer applies to the assets of the QDOT, as of the date the surviving spouse becomes a U.S. citizen, the DSUE amount is considered final and is available for application by the surviving spouse. See Regulations sections 20.2010-2(c)(4), 20.2010-3(c)(3), and 25.2505-2(d)(3). Check the appropriate box in this section and see the instructions for Schedule M if more information is needed about QDOT. Section C. DSUE Amount Portable to Decedent's Surviving Spouse. Complete Section C only if electing portability of the DSUE amount to the surviving spouse. On line 1, enter the decedent’s applicable exclusion amount from Part 2—Tax Computation, line 9d. The applicable exclusion amount is the sum of the basic exclusion amount for the year of death, any DSUE amount received from a predeceased spouse, if applicable, and any Restored Exclusion Amount. Line 2 is reserved. On line 3, enter the value of the cumulative lifetime gifts on which gift tax was paid or payable. This amount is figured on line 6 of the Line 7 Worksheet, Part B, as the total of Row (r) from the Line 7 Worksheet, Part A. Enter the amount as it appears on line 6 of the Line 7 Worksheet, Part B. Figure the unused exclusion amount on line 9. The DSUE amount available to the surviving spouse will be the lesser of this amount or the basic exclusion amount shown on line 9a of Part 2—Tax Computation. Enter the DSUE amount as determined on line 10. Section D. DSUE Amount Received From Predeceased Spouse(s). Complete Section D if the decedent was a surviving spouse who received a DSUE amount from one or more predeceased spouses. Section D requests information on all DSUE amounts received from the decedent’s last deceased spouse and any previously deceased spouses. Each line in the chart should reflect a different predeceased spouse; enter the calendar year(s) in column F. In Part 1, provide information on the decedent’s last deceased spouse. In Part 2, provide information as requested if the decedent had any other predeceased spouse whose executor made the portability election. Any remaining DSUE amount which was not used prior to the death of a subsequent spouse is not considered in this calculation and cannot be applied against any taxable transfer. In column E, total only the amounts of DSUE received and used from spouses who died before the decedent’s last deceased spouse. Add this amount to the amount from Part 1, column D, if any, to determine the decedent’s total DSUE amount. Schedule A—Real Estate If any assets to which the special rule of Regulations section 20.2010-2(a)(7)(ii) applies are reported on this schedule, do not enter any value in the last three columns. See the instructions for line 10 of Part 5—Recapitulation for information on how to estimate and report the value of these assets. If the total gross estate contains any real estate, complete Schedule A and file it with the return. On Schedule A, list real estate the decedent owned or had contracted to purchase. Number each parcel in the left-hand column. Describe the real estate in enough detail so that the IRS can easily locate it for inspection and valuation. For each parcel of real estate, report the area and, if the parcel is improved, describe the improvements. For city or town property, report the street and number, ward, subdivision, block and lot, etc. For rural property, report the township, range, landmarks, etc. If any item of real estate is subject to a mortgage for which the decedent's estate is liable, that is, if the indebtedness may be charged against other property of the estate that is not subject to that mortgage, or if the CAUTION ! Instructions for Form 706 (Rev. 09-2021) -19-