subject to her will, which pro- ceive all the property outright. Her erty Dave disclaims will pass instead to their children in vides that her surviving husband, Dave lames, is to re will further states that any prop equal shares. Annie's gross estate is $6.3 million, and her Sec. $300,000. Dave, who is in poor health, already owns about $5 million of property. What tax issues should Dave James consider with respect to the property bequeathed to him by his wife? 2053 deductions are