28. D transferred $25,000,000 to irrevocable trust ("T") in Year 1. T provided that the trust would pay income to D's three adult children (A, B and C) in equal shares, and upon D's death the remainder would be divided equally among them. The trust also provided, that D could distribute principal to any of D's three children, as D determined, provided all of the beneficiaries (A, B and C) agreed to such distribution. In Year 10, D, with the consent of A, B and C, distributed $1,000,000 to A. D died in Year 15 when the trust had a value of $28,000,000. Which of the following is a correct statement?

a. D will include $28,000,000 in D's Gross Estate b. D has made a gift of $25,000,000 in Year 1 c. D has made a gift of $1,000,000 in Year 10 d. Both a and b are correct

e. Both a and c are correct