Code Section 2053.

2.5) When D died, D had only $50,000 in a bank account and no other assets. However, this is the same D encountered in question (2) above, and D had been receiving $90,000 income annually from the trust, the corpus of which had a value of $11,560,000 at D's death. D was personally liable for obligations in the amount of $100,000 when D died. This is, therefore, a taxable estate. Could Congress properly take the position that the deduction for claims should not exceed $50,000 since that is all D had from which claims can be paid, and that it is of no estate tax significance if C pays $50,000 of D's claims from C's own separate funds? What has Congress done about this? Explain