C:13-29 Annie James died early in 2020. All her property passed subject to her will, which provides that her surviving husband, Dave James, is to receive all the property outright. Her will further states that any property Dave disclaims will pass instead to their children in equal shares. Annie's gross estate is $13.3 million, and her Sec. 2053 deductions are $300,000. Dave, who is in poor health, already owns about $5 million of property. What tax issues should Dave James consider with respect to the property bequeathed to him by his wife?

C:13-30 Assume the same facts as in Problem C:13-29 except that Annie's will leaves all her property to a QTIP trust for Dave for life with the remainder to their children. What tax issues should Dave James and the estate's executor consider with respect to the property that passes to the QTIP trust?