No. The mother would not need to have a court order or court document to file the return. When walking through the steps to file, in the personal info section, there is a box to check that says this person died in 2025. She will need to check that box. If the deceased is due a refund, then she will need to fill out form 1310 which can be done in TurboTax as well to claim the refund.
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