Mr. and Mrs. Holt made no taxable gifts during their lifetimes. Mrs. Holt died two years ago. Her estate tax return shows that she owed no estate tax and had an $800,000 unused lifetime exclusion. Mr. Hold died in 2015. The lifetime transfer tax exclusion available to his estate is $6,230,000.

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Since Mrs. Holt made no taxable gifts during her lifetime and her estate owed no estate tax, her unused lifetime exclusion of $800,000 can be transferred to her husband, increasing his lifetime transfer tax exclusion from the base amount of $5,340,000 in 2015 to $6,140,000. Therefore, Mr. Holt's estate has a lifetime transfer tax exclusion of $6,230,000, which is greater than the base amount due to the unused exclusion amount transferred from his wife.

Mr and Mrs