Husband and Wife, residents of a separate property state, were divorced two years before Husband's death. As part of the divorce agreement (which complied with Section 2516), Wife surrendered her marital rights and Husband agreed to pay Wife $10,000 a year until her death or remarriage. Assuming the alternate valuation date was not selected, what are the probable estate tax consequences with respect to Wife's claim? [Apply Reg. section 20.2053-4(d)(6)(i)].