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1 . Taxpayer A ( A ) has $ 1 0 0 , 0 0 0 , 0 0 0 cash. On January 1 ,

1. Taxpayer A (A) has $100,000,000 cash. On January 1,2020, A transferred $5,000,000 to trust T. The terms of trust T were that A would receive $1,000,000 per year for 5 years, and at the end of 5 years, the remainder (the assets still in the trust) would be distributed to As son (S). The interest rate (AFR) at date of transfer was 5%. As it turns out, T earned $500,000 per year (i.e. the remainder was $2,500,000.
a. What is As taxable gift in 2020, if any?
b. What portion of the remainder is included in As gross estate?
c. What if A died in 2023?

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