A $99,600 credit, not a dollar-one cliff
Verified against real examples
A $2,500,000 estate owes about $39,200. A $3,000,000 estate owes about $82,400. A $5,000,000 estate owes about $292,000. These figures come from applying the statute's own formula — the old federal state death tax credit table, minus the $99,600 cap.
No portability, no separate inheritance tax
Each spouse has their own $2,000,000 threshold that cannot combine or transfer to the survivor — see Portability & Marital Deduction for what Massachusetts couples use instead. Massachusetts also has no separate inheritance tax; only the estate itself is taxed.