Under the current $5.6 million exemption per person, there is no estate tax in this case.   But at the time, the exemption was only $1.5 million Federal (+ state), and the federal rate was 45%.  And Obama wanted to make the exemption lower.

My comment to my daughter was that it would cost her $1 million OF her inheritance, which was projected to be considerably more than a million.  She chose pretty good grandparents who bought considerable land in the foothills when it was cheap and now it isn't.