See https://scholarlycommons.law.hofstra.edu/cgi/viewcontent.cgi?article=1035&context=acteclj
Not exactly an answer, but another data point.
Regardless, Section 645 elections are complex and you should seek guidance from a local tax professional and/or legal counsel.
https://taxexperts.naea.org/listing/service/estates-gifts-trusts
https://www.avvo.com/estate-planning-lawyer.html
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