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Hmm, payee was not alive to cash the checks so checks issued in error were not received by payee/decedent.

More Hmmm. Checks payable to a decedent could certainly be negotiated by the decedent's estate. So we're back to constructive receipt, but by the estate and not the decedent. I think.

That would be my position. Anything paid after the date of death belongs to the estate and needs to be reported/corrected there.

And that would mean the income on the 1099 should be apportioned between the decedent's final return and the estate's income tax return. But now we're back to a mismatch between 1099s and the return, which will generally generate correspondence.

Maybe I've been fortunate, but I've never had a CP2000 document mismatch notice on a decedent's final return and the returns always have income reported to the decedent that is allocated to the estate.

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