Harold and Maude were married and lived in a common-law state. Maude died in 2018 with a taxable estate of $25.80 million and left it all to Harold. Maude's executor filed a timely estate tax return claiming the marital deduction for the property left to Harold including a valid portability election. Harold died this year, leaving the entire $25.80 million to their three children.

Calculate how much estate tax is due from Harold's estate under the following two alternatives:

A. Assume that neither Harold nor Maude had made any taxable gifts prior to this year.

B. Assume that Harold and Maude each made a $1 million taxable gift in 2011 and offset the gift tax at that time with the applicable credit.