Rich N. Famous is a new client of yours. Rich's wife passed away in 2013 leaving her entire estate, valued at $2 million, to her children from a previous marriage. If Rich were to pass away in 2014 without having remarried, with an estate valued at $12 million, what is the least amount of estate tax that would be due? Assume that neither Rich nor his deceased wife made any lifetime taxable gifts. Are there any other facts or rules on which your conclusion might depend?
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§ 2010(c).