Can a state impose an estate tax on the termination of an income interest in a trust

QUESTIONS PRESENTED FOR REVIEW 1. Can a state impose an estate tax on the termination of an income interest in a trust solely on the basis that a federal election to qualify such trust for the federal marital deduction was made in the estate of the decedent's predeceased spouse, when such predeceased spouse died a domiciliary of another state, and the decedent did not have a power of appointment over the trust assets? 2. Did this Court’s ruling in Fernandez v. Weiner, 326 U.S. 340 (1945) (“Fernandez”) limit or overrule its ruling in Coolidge v. Long, 282 U.S. 582 (1931)(“Coolidge”)? 3. Is the termination of an income interest in a QTIP trust upon the death of the surviving spouse who did not hold a power of appointment over the trust assets and where there was no state QTIP election made upon the death of the predeceased spouse, a transfer causing sufficient nexus to a state to grant it taxing authority under the Due Process Clause of the Fourteenth Amendment to the United States Constitution? i