Filing turns on a sum the executor must build: adjusted taxable gifts made after 1976, plus any pre-1977 specific exemption, plus the gross estate at death. Where that sum tops the basic exclusion amount, the estate files. For decedents who died in 2026 the basic exclusion amount is $15,000,000, paired with a basic credit amount of $5,945,800; for 2025 decedents the basic exclusion amount was $13,990,000, so the year of death sets the threshold. The unified credit (the applicable credit) then offsets the estate tax: the tentative tax is figured on the combined amount — the taxable estate with the line 4 adjusted taxable gifts added back — and reduced by gift taxes payable and the applicable credit, so lifetime taxable gifts and the death-time estate share one combined exclusion. A small estate can still file to elect portability of the unused exclusion to the surviving spouse. The tax itself is levied on the entire taxable estate rather than on any one beneficiary's share.
Worked example
Theo died in 2026 with a $14,200,000 gross estate and $1,100,000 of post-1976 adjusted taxable gifts. The filing total is \(14{,}200{,}000 + 1{,}100{,}000 = 15{,}300{,}000\), or $15,300,000, which clears $15,000,000, so the executor files Form 706. On the return the tentative tax is figured on the taxable estate with the $1,100,000 of adjusted taxable gifts added back, then reduced by gift taxes payable and the applicable credit; any credit unused against gift tax remains available against the estate tax, which is why the return reconciles lifetime and death transfers together.