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2. S transfers $1,000,000 to T in an irrevocable trust, to pay the income to A, age 32, for ten years, remainder to B. Sreservesthe

2. S transfers $1,000,000 to T in an irrevocable trust, to pay the income to A, age 32, for ten years, remainder to B. Sreservesthe power to substitute or add income beneficiaries. Which of the following statements are correct? Explain answer

A. The transfer of the income interest to A was complete for gift tax purposes.

B. B's interest was vested in and was a completed gift.

C. B's interest would qualify for the annual exclusion.

D. Only B. and C. are correct

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