First of all, nowhere in Publication 529 is it stated that "amounts entered in Box 11 with a Code of 'A' are for information purposes only" nor does that publication specifically mention "excess deductions allowed a beneficiary on termination of an estate or trust".
However, you have officially highlighted the issue; there is nowhere to properly deduct those excess deductions on termination that are NOT SUBJECT to the 2% floor yet IRC §?67(e) and Treas. Reg. §1.67-4 specifically reference the full deductibility of costs paid by an estate or non-grantor trust that are not subject to the 2% floor.
Therefore, the IRS needs to provide guidance on this issue since there is an ambiguity.
