Just so this is clear, the cancellation of debt actually converts the debt into income (per the 1099-C).
As a result, a 1099-C received postmortem is income to the estate and, technically, should be reported on an income tax return for the estate (Form 1041).
In the event, the estate has no assets from which expenses can be paid (e.g., it is insolvent), the estate can exclude the COD income by filing Form 982.
[Note: in this instance, the expenses would most likely be limited to income tax due]
