Matter of Estate of Mason

OPINION

DRUKE, Chief Judge.

Jane Mason, widowed and childless, died testate in 1992. Her will made three specific bequests of $10,000 each and distributed the residue equally to appellee and his sister. The funds in three bank accounts passed to appellant outside the will because Mason had made him a joint tenant on the accounts before her death.

Mason’s gross estate exceeded $5 million, including the funds appellant received from the bank accounts, and resulted in a total estate tax liability of about $2.2 million. Because the will was silent on the payment of estate taxes, appellant, as…