Although the federal estate tax is imposed on the "transfer" of property, the amount of the levy is a specified percentage of the taxable estate. Correct computation of the tax depends, therefore, upon accurate identification of the property included in the taxable estate. However, the determination and application of the rules governing identification are relatively uncharted areas.
Charles L. Lowndes & Richard B. Stephens,
Identification of Property Subject to the Federal Estate Tax,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol65/iss1/5