I have a final year estate tax return with excess deductions consisting of mortgage interest paid on the decedents‘ personal residence and tax preparation fees. Assuming the beneficiaries each only have one residence of their own and fall way under the mortgage limits of $750k, can they each deduct in 2019 their proportional share of the mortgage interest allocated to them as an excess deduction under these proposed Regs? I believe the answer is yes but I want to make sure.