When S1 died, his executor was given broad authority over his $9,000,000 estate. The executor is considering two options --
Fund a QTIP trust with S1's estate and make a QTIP election to reduce his taxable estate to an amount that equals S1's AEA or
Transfer S1's estate to his wife and elect AEA portability so that the wife can use his AEA when she dies.
Assume that S1's estate includes property that is likely to double (or more) in value before his wife's death, why would the second option be a mistake?