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Thanks.  But, this seems like a circular issue.  If one's estate includes all of one's assets, it should be irrelevant whether they are in or out of a trust.  The estate is the estate.  By taxing a trust, which is part of one's estate, the IRS is essentially saying that the $11.58MIL limit "doesn't hold water".  Rather, they can tax any portion of one's estate they want regardless of the $11.58MIL exclusion.  I know you can't solve this regulatory issue - just blowing off a little steam.  Thank for your assistance.