Thank you for your comments.  After doing extensive research on the change in treatment of Excess Deductions on termination, the regulations follow up of Notice 2018-61, TD 9918 and other publications, points in another directions.  It was stated that this portion are the Excess Deductions on Form 1041 would have been itemized deductions, if paid by an individual, including taxes and interest.  These expenses should be entered in their proper location on the Schedule A and broken down into individual categories claiming them as either an adjustment to income, a non-miscellaneous itemized deduction on Schedule A or as a miscellaneous itemized deduction.  Prior to 2018 these Excess Deductions were claimed by the beneficiary as a "2% Miscellaneous Itemized Deduction." 

This was my last out reach and I still don't feel I can make an argument that I am comfortable reporting.

Thank you and I appreciate your time.