The federal estate tax is, in a sense, voluntary, because the estate tax charitable deduction allowed under Internal Revenue Code Section 2055(a) can reduce any taxable estate to zero. On the other hand, relatively few estates are now subject to federal estate tax because of the estate tax exemption of $5 million.1 Yet, even for owners of estates with assets of less than $5 million, the provisions of Section 2055, and the corresponding regulations, can be important. Moreover, for
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