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Pat asks:

<<There is more upfront and after this part of the article, but my point is in the above where it talks of generosity by Congress. Does anyone have an answer as to why both taxes wouldn't apply regardless if the beneficiary is "The estate", or your children ????>>

Both taxes would apply regardless of who the beneficiary is. The generosity referred to alludes to the fact that for income tax purposes there is a partial credit allowed to beneficiaries for any increase in the estate taxes that resulted from the inclusion of the IRA in the estate. That doesn't apply in all cases, and it doesn't eliminate the income tax burden at all, but serves to reduce (possibly) the total income taxes due.

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