IRA estate planning

I have new client: husband and wife both in 90’s and poor health; may pass away in 2012 or 2013. Estate is $2.2M with $1.2M in husband’s IRA. Children are concerned with exposure to estate tax on amount in excess of $2M in 2013. A couple of thoughts: (1) gift sufficient amount in 2012 to lower overall estate. (2) change beneficiary on IRA to pass some directly to children and balance to wife, works if husband passes first.
Any other ideas?



Roth conversion.



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