A soft-pedal version of the IRS ruling is included on page 4 of the W-9. Unfortunately, the way it's worded suggests that, by playing with the name of the account, one could avoid having to use the estate's EIN on an account.
However, since there is no question that an estate is an entity subject to CIP requirements as of October 1, I believe the discussion is moot. The estate is the customer, and you must obtain its TIN.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8