Even some liberals are coming to the conclusion that taxing an estate at the owner's death is bad public policy. They note that it is a tax on non-consumption and that the simplest way for the wealthy to avoid the tax is to spend everything.

• The tax, in place in some form since 1916, has raised little money and some economists argue it might even cost the government money by encouraging wasteful forms of property transfer and ownership.

• Estate taxation is so unpopular here and abroad that Congress has just raised the exemption level from $600,000 to $1 million by 2006, and Australia, Canada and Israel have recently gone so far as repealing such taxes.

• In 1982 Californians voted overwhelmingly to abolish an inheritance tax that applied to only one in 20 state residents.

• Critics argue that those who die with large amounts of wealth have worked and saved, contributed to investment capital formation, and refrained from spending all their wealth on themselves.

Liberal opponents of the tax contend that for these reasons it should be abolished -- or, at the very least, restructured.