Assume D, a widower, made no prior taxable gifts. Consider 2501, 2502, 2505, and 6019.

b. In 2019, D makes a taxable gift in the amount of $11,500,000. What are the gift tax ramifications of the transfer? What is the amount of the gift tax payable? Must D file a gift tax return?

c. What would be the amount of the gift tax due if D made no gifts before 2019 but made taxable gifts of $11,500,000 in 2019? What are the gift tax ramifications of the transfer? What is the amount of the gift tax payable?

d How would the answers to b and c change if the taxable gifts were made in 2020 instead of in 2019? Carefully consider 2010(c)(2)(B) in relation to 2502(a)(1).