1. S1 died June 7, 2009, survived by 60-year-old S2. The 7520 rate was 6%. They had an ABC estate plan. At S1s death their holdings had the following net value:

S1s separate $9,350,000

S2s separate $2,400,000

Total value $11,750,000

Determine as of S1s death: (i) the value of Trusts A, B, and C; (ii) the QTIP fraction that resulted in S1s taxable estate being $6,300,000; and (iii) the estate tax. S2 died May 12, 2015, and the trusts had the following values (assumes estate tax at S1's death is allocated between Trusts B & C in proportion to pre-tax funding values and 40% appreciation in value):

Trust A: $3,360,000 Trust B: $4,239,679 Trust C: $7,086,321

B.Given the values for the three trusts: (i) show how one arrives at $7,054,578 as S2s taxable estate; and (ii) determine the federal estate tax before considering the PTC.

C.Determine credit limit one. Assume a 6% AFR.

D.Determine: (i) S2s reduced taxable estate; and (ii) credit limit two.

E.Determine: (i) the PTC after adjusting for time; and (ii) the estate tax.

F.What if S2 had died October 12, 2015?