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Under either formulation of purpose, that is, the “unified” approach or the “fairness” approach, in issuing its regulations, the IRS would be compelled to use the basic exclusion amount in effect the time of the decedent’s death for purpose of computing the offset under Section 2001(b)(2), assuming the decedent’s death occurred after 2025.  However, the problem remains that Congress has provided us with no express purpose to Section 2001(g), and therefore we can still only speculate as to how the IRS will ultimately handle this issue.

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