Please help work below facts into the estate tax formula for John Doe, who died June 17, 2023. John (born July 2, 1940) resided at 30 Rockefeller Plaza, New York, NY 10112 and was a lifelong NY resident. His first wife, Jane Doe, passed away in 2005. In 2010, he married Eliza Smith, a U.S. citizen, who survives him. John has three children (Amy, Brady, and Candy Doe), who also survive him, from his first marriage to Jane Doe.

The following properties were discovered upon John's death, listed below at date of death values.

• Primary residence with a value of $850,000. This was purchased by John in 2012 and titled in the names of John Doe and Eliza Smith, joint tenants with right of survivorship.

• Household furnishings acquired by John during his first marriage and valued at $140,000 when he died.

• $1 million cash in a money market account in John's name. On his date of death, John also had $2,200 of accrued interest for the account, that is not reflected in the account balance.

• $30,200 checking account at Empire State Bank in the names of John Doe and Eliza Smith as tenants in common.

• Stock portfolio in John's name worth $14.3 million.

• $1 million life insurance policy. John had originally purchased the policy in 2005 and continued to hold incidents of ownership upon his death. The beneficiary of the policy is John's estate.

• QTIP trust established with a bank trustee by John's first wife, Jane Doe, upon her death in 2005. Her executor claimed a 60% marital deduction on the trust, then valued at $750,000. John received all of the income monthly for life, and the remainder is to go to the three Doe children in equal shares. The trust was valued at $1.8 million upon John's death.

• Trust with a value of $500,000. This trust was created under the will of John's uncle, Richard Doe, who died in 2000. John was entitled to receive all the income annually for life and was granted the power to will the property to such of his descendants as he so desired with the specification that, if he did not exercise the power, the property passes to Richard's former housekeeper, Yvette Jones.

John's will included the following provisions:

• I bequeath to my spouse Eliza Smith all of my household furnishings.
• To the San Diego Humane Society, I leave $50,000.
• To a trust with Bank of America, I leave $500,000. My wife, Eliza Smith, is to receive all the trust income quarterly for life, and upon her death the remainder is to be divided equally amongst my three children or their estates.
• I leave my sister, Jeannette Doe, $100,000, but if she disclaims this amount, it will go instead to my beloved wife, Eliza Smith.
• I appoint the property in the trust from my uncle, Richard Doe, to Brady Doe (my son).
• The rest of my property I leave to Amy Doe (my first-born daughter).

Other pertinent information includes:

• As of his date of death, John owed his country club $800 for monthly dues.
• The cost of John's funeral, including flowers and a tombstone totaled $15,000.
• His accountant's, attorney's, and executor's fees will be $120,000.
• Jeannette Doe made a qualified disclaimer of the $100,000 bequest.
• John's executor, Larry Low, will make elections that result in the lowest estate tax currently payable.
• John did not make any taxable gifts during his life.
• Assume that there were no state death taxes.