The IRS has issued five identical private letter rulings, apparently to five different parties involved in the same transaction, confirming that a court-approved reformation of a trust in accordance with § 415 of the Uniform Trust Code would be respected for federal estate and gift tax purposes retroactive to the date of the creation of the trust, when there was clear and convincing evidence that the trust documents were drafted incorrectly and contrary to the settlor’s intentions.  Although the name of the state was redacted from the ruling, the state law in question appears to be Pennsylvania, because the text of the statute quoted by the ruling includes a sentence specifically authorizing retroactive reformations and that sentence appears in Pennsylvania’s version of § 415 (20 Pa.C.S. § 7740.5) but not in the version that was approved by the National Conference of Commissioners on Uniform State Laws.  PLRs 201442042, 201442043, 201442044, 201442045, and 201442046.