> As I recall - and it's been a while - Modigliani argued against a
> high inheritance estimate, no doubt because he was fond of his life
> cycle hypothesis. I don't recall the divisions being as stark as
> this, though; I recall 50% being quite a conservative estimate.
It was Justice O'Connor writing for a unanimous court in '87's Hodel vs. Irving that overturned all progress on taxing inheritance by claiming all previous SC decisions, especially Irving Trust vs Day failed to see that they constituted a takings [Jefferson has been turning in his grave ever since]