Consult the case Estate of Edward S. Redstone, 145 T.C. No. 11 (2016), a rather complicated case, and answer the following uncomplicated questions:

a. When did the alleged gift occur, and when did the IRS issue a notice of deficiency?

b. Why was the IRS able to argue that gift tax was owed, given the year the alleged gift occurred?

c. How much monetary compensation did Edward Redstone receive for the shares transferred to his children, Ruth Ann and Michael?

d. What did the Tax Court decide, and what was its rationale?