August Couch died July 15, 2015. His estate tax return, filed on January 4, 2016, showed a taxable estate of \($3.1\) million with no estate tax payable. Form 706, Part 6, addressing Portability of Deceased Spousal Unused Exclusion (DSUE), showed the DSUE amount portable to his surviving spouse (June Couch) as \($2.33\) million (\($5,430,000\) − \($3,100,000).\) August had made taxable gifts of \($1\) million in 2014, and these gifts (which triggered no gift tax liability) were reported on a timely filed Form 709. The gifts, however, did not