(a) Returns by executor
(1) Citizens or residents In all cases where the gross estate at the death of a citizen or resident exceeds the applicable exclusion amount in effect under section
2010 (c) for the calendar year which includes the date of death, the executor shall make a return with respect to the estate tax imposed by subtitle B.
(2) Nonresidents not citizens of the United States
In the case of the estate of every nonresident not a citizen of the United States if that part of the gross estate which is situated in the United States exceeds $60,000, the executor shall make a return with respect to the estate tax imposed by subtitle B.
(3) Adjustment for certain gifts The amount applicable under paragraph (1) and the amount set forth in paragraph (2) shall each be reduced (but not below zero) by the sum of
(A) the amount of the adjusted taxable gifts (within the meaning of section
2001 (b)) made by the decedent after December 31, 1976, plus
(B) the aggregate amount allowed as a specific exemption under section
2521 (as in effect before its repeal by the Tax Reform Act of 1976) with respect to gifts made by the decedent after September 8, 1976.
