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Jiang and Bao are married. Jiang is a U.S. citizen and Bao does not have citizenship yet. Assuming Jiang dies and there are no other

Jiang and Bao are married. Jiang is a U.S. citizen and Bao does not have citizenship yet. Assuming Jiang dies and there are no other relatives or children, how much would Bao need to put in a QDOT to avoid estate tax?

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