I have a deceased client that I am preparing an estate tax return for (For 706),  The spouse died several years ago and an estate tax return was prepared and filed.  Estate taxes were paid only for the state  with the filing of Form 706.  The estate was valued at about 2.5 million and included a revocable trust.  A new revocable trust was created with the balance of the spouse's estate in the name of the spouse with the surviving spouse as the beneficiary.  My question is this:  Is the revocable trust included in my client's estate (the surviving spouse)?  Or is only the increase in value included in the surviving spouse's estate since taxes have already been paid on the assets used to set up the trust?