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d.If Jane and John fail to take advantage of the portable estate exemption by forgetting to file IRS Form 706 at the death of

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d.If Jane and John fail to take advantage of the portable estate exemption by forgetting to file IRS Form 706 at the death of the first spouse, will there be a tax liability this year, assuming the second spouse also passes shortly thereafter? Describe an estate planning strategy that can be used to minimize any estate tax liability in this situation.

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