§3195

3195(c)(4)(B) (emphasis added). This directs the Secretary of Agriculture to establish a "proportion" for each state equal to the value produced by each state divided by, or which "bears to," the value produced in all states. See 1_4 The next sentence then refers to this "proportion" as "the proportionate value * * * for each State." Id. That'

Section 20.2107-1, Estate Tax Regs., provides that ifa nonresident expatriate decedent owns or is considered to own a certain amount ofthe voting shares in a foreign corporation at the time ofhis death, his gross estate must include an amount based upon the FMV ofhis percentage ownership interest in the foreign corporation and the portion ofthe for