Jeung Hong, a widower, did in March 2019. His gross estate was 514.5 million and, at the time of his death, he owed debts of $60,000. His will made a bequest of $200,000 to his undergraduate alma mater and left the rest of his property to his children. His administrative expenses were $75,000. What tax issues should the estate's CPA consider when preparing Jeung's estate tax return and his estate's income tax return?