The gift tax that is paid after death for net gifts made in the year of death is included in the gross estate under IRC section 2035 and the estate is not entitled to any deduction for the gift tax as a debt of the estate under IRC section 2053.  Under state law, no part of the federal estate tax that is payable will be apportioned to the donees even though the values of the taxable gifts are included in the calculation of the tax and the gift tax is included in the gross estate.  Estate of Sheldon C. Sommers v. Commissioner, 149 T.C. No. 8 (8/22/2017).