Stuart Scroggins died in June of the current year. Among the provisions in his will is one that benefits your client, Samantha Scroggins Valdez. This provision reads as follows:

I leave $1.5 million cash to my daughter Samantha. If she predeceases me, I leave this amount instead to my distant cousin, Joseph Jimerson.

Samantha, who is quite wealthy, indicated to you that she has no need for this amount of cash. In an earlier meeting she mentioned to you that she would like to fund a scholarship endowment at her alma mater. The minimum required for such an endowment is $1.75 million, which Samantha could easily fund even without the inheritance from her father. Under state law, if Samantha disclaims the bequest, she will be treated as predeceasing her father. Joseph, the distant cousin, is not wealthy and could use any inheritance he might receive. Samantha, however, has admitted to you that she does not like him or his family. To date, Samantha has made no taxable gifts, and she is in the top income tax bracket.

Prepare a critical analysis of Samantha’s alternatives and their tax consequences so you can explain them to her.