13. In 2021, Amy has a remaining GST exemption of $10 million. Amy transfers $8 Million into an irrevocable trust that provides income to her wife, Betty for Betty's life. The remainder beneficiary of the Trust is Amy and Betty's son, Charlie or Charlie's children. Charlie has a son, Greg. Because the contingent beneficiary, Charlie's son Greg, is a skip person, Amy's CPA allocates GST exemption. Amy makes both a QTIP election and a reverse QTIP election with respect to the trust. Two years after the trust is set up, in 2023, Charlie dies in a tragic accident. At the time of Charlie's death, the trust has appreciated to $10 million. Amy should