The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (Tax Relief Act of 2010) (P.L. 111-312) provides a two-year extension of the exclusion from gross income for qualified charitable distributions up to $100,000 from a traditional or Roth IRA (Code Sec. 408(d)(8)(F)). A special rule permits a taxpayer to make an election to treat a qualified charitable distribution made in January 2011 as having been made on December 31, 2010