DAVID A. NELSON, Circuit Judge.
This is a federal estate tax case that involves a will executed in 1978. The will contained a provision leaving the testator's wife an amount equal to the maximum marital deduction allowed by federal law. After the will was signed, the then-existing limits on the marital deduction were removed by the Economic Recovery and Tax Act of 1981 ("ERTA"). The testator died two years later without having changed his will.
Under a "transitional...
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