Tax Notes, a weekly journal for tax lawyers and accountants, reaches a similar conclusion.

The collection was published in the Nov. 14 issue of "Tax Notes," a journal for tax specialists.

An article about Ms. Welling is scheduled to appear today in the electronic version of Tax Notes, a trade magazine, at www.taxanalysts.com.

Tax Notes is a nonprofit journal that reports on tax systems worldwide.

The decision was issued Tuesday and reported yesterday in Tax Notes.

Lee Sheppard is a tax commentator and contributing editor at Tax Notes.

The article, which appears in today's edition of Tax Notes, a nonprofit tax policy journal, is available online at www.taxanalysts.com.

But it was too late to keep the estimate from being picked up by Tax Notes, an authoritative publication in the field, and given fresh impetus.

Yet the article in Tax Notes seems likely to have a profound effect on the debate over estate taxes, experts say.

"The obstacles to resolution are daunting," said Tax Notes, an industry publication, in a late 1988 study of the issue.