I don't have HBP on me right now, but wasn't there some mention of how the gargoyle at the base of the stairwell leading up to the headmaster's study didn't recognize Umbridge as the rightful headmaster? For the same reason, I think Umbridge wouldn't have a portrait, and that Snape would, if he had died, of course.
Or not. I can imagine Snape refusing to have a portrait in the headmaster's study, too.
Well, he never really seemed to like teaching or students and probably wouldn't like to be bothered with anything related to Hogwarts anymore. After all, his worst memory happened there. As sad as it sounds, I think he's prefer not to have to live on as a portrait and just rest for eternity.... But that's just my humble opinion.
Or not. I can imagine Snape refusing to have a portrait in the headmaster's study, too.
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