Dyer, et al. v. State, et al., No. F052848, 2008 Cal. App. Unpub. LEXIS 1834 (Cal. Ct. App. Mar. 3, 2008)

(state (California) estate tax may only be assessed in an amount equal to the maximum allowable amount of the credit for state death taxes permitted under the I.R.C., and if the tax does not result in a total state and federal death tax liability in excess of the liability owed to the U.S.).