Matt Patterson died in early 2023 with a \($16.5\) million gross estate and no deductions other than a potential marital deduction. He bequeathed all his property to his spouse, Nancy, with the provision that, if Nancy predeceases him, the couple’s two adult children will receive the entire property in equal amounts. Nancy survived Matt, but she has a recently diagnosed terminal illness. Nancy’s own assets have an estimated \($10\) million fair market value as of Matt’s date of death. Her estate will likely have only minimal deductions. Her current will leaves her property 50% each to the two children. Your manager will soon meet with Nancy, who wants to discuss the implications of disclaiming Matt’s bequest to her.

Your manager requests that you prepare projections of the combined estate tax liability of Matt and Nancy if Nancy disclaims and does not disclaim. Also make a recommendation to Nancy. Assume the assets do not appreciate by Nancy’s date of death. Nancy requested using the assumption that her death will occur near the end of 2023, at the latest.