When D died in $2022,$ D had only $$50,000\mathrm{.}00$ in a bank account and na other assets. However, this is the same D encountered in question $2$ above, and $0$ had been recelving $$90,000\mathrm{.}00$ income annually from the trust, the corpus of which had a value of $$12,110,000\mathrm{.}00$ at $D^{\text{'}}s$ death. D was personally liable for obligations in the amount of $$100,000\mathrm{.}00$ when $D$ died. This is therefore a taxable estate. Could Congress properly take the position that the deduction for claims should not exceed $$50,000\mathrm{.}00$ since that is all D had from which claims could be paid, and that it is of no estate tax

significance if C pays $$50,000\mathrm{.}00$ of D$\text{'}$s claim from C$\text{'}$s own separate funds? What has Congress done about this?