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Is it clearly erroneous for an executor to fail to take the marital deduction on QTIP property when doing so would eliminate taxes on S1's

Is it clearly erroneous for an executor to fail to take the marital deduction on QTIP property when doing so would eliminate taxes on S1's estate?

a. Can a QTIP arrangement, and a disclaimer provision be alternative methods of achieving a common objective? Why or why not?

b. Which places greater property rights in the hands of S2? Explain.

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