A series of private letter rulings over the past several years seemed to indicate that a gift to a predeceased spouse would qualify for the gift tax marital deduction and enable use of that spouse's estate tax applicable exclusion amount. In Estate of Lee, the Tax Court, stating the obvious, recently held that a bequest to a predeceased spouse does not qualify for the estate tax marital deduction. The Tax Court's decision, equally applicable in the gift tax marital deduction context,
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