Extension of time allowed to make reverse QTIP election

In PLR 200005030, the decedent's will divided the residue between a marital trust and a family trust. The marital trust was to be further divided into a GST exempt trust and a GST-nonexempt trust. (The Service notes in the ruling that the Form 706 was prepared by an accounting firm and reviewed by lawyers.) On Schedule M, the executors made a QTIP election with respect to the marital trust. On Schedule R, they allocated the decedent's $1 million GST exemption to the marital trust, but did not indicate that the marital trust was going to be divided into two trusts.