Excess 67(e) Deductions: From Estate, to Trust, then to Beneficiaries?

I'm working on filing the final year income tax returns for the estate I manage, on a short year return for 2025. The arrangement made in court is that everything in the estate will be transferred to the trust that was set up by the decedent, then the trustee can distribute the assets to the beneficiaries and dissolve the trust, ideally within the same year.

My issue is, can excess 67(e) deductions for AGI on the final year of the estate income tax return flow to the trust first on a k-1, then to the beneficiaries of the trust on a subsequent k-1, and still retain its character as a deduction for AGI? I haven't been able to find any official guidance on this (so please direct me to any that I missed), but I feel since the spirit of the law is that the deductions should retain their character, that it should apply here as well.

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