At S1’s death their holdings had the following net value: 

S1’s separate $9,350,000 

S2’s separate $2,400,000 

Total value $11,750,000 --------------------------------------------------- 

S2 died May 12, 2015, and the trusts had the following values (assumes estate tax at S1's death is allocated between Trusts B & C in proportion to pre-tax funding values and 40% appreciation in value): 

Trust A: $3,360,000 

Trust B: $4,239,679 

Trust C: $7,086,321 -----------------------------------------------

Determine the federal estate tax before considering the PTC.