31. D created an irrevocable trust on January 1, 2020.D transferred assets worth $2,000,000 to the trust. The terms of the trust were that D would receive $500,000 yearly payment for 4 years. At the end of 4 years, the trust would terminate and the remainder would be distributed to D's child. Assuming the interest rate (7520) is 5% at all times.

a. Has D made a taxable gift? If so, in what amount?

b. Would your answer to (a) change, if in fact the FMV of the trust were $1,500,000 at the end of 4 years?