At a time when the annual exclusion is $12,000 per year, Grant established an irrevocable trust with $800,000 in assets. The trust gives income for life to Betty and Bob. Once one dies, the survivor is to receive all income until his or her death, at which time the trust terminates in favor of Randy or his estate. So long as Grant is alive, he can direct the allocation of the income between Betty and Bob, but if Grant fails to make an allocation, the trustee must divide the income equally.

The total value of the completed gifts (before annual exclusions) when this trust was established is:

a the $800,000 value of the trust.

b zero, since the gift is incomplete until Grant releases his right to allocate income or one of the income beneficiaries dies.

c the value of the income allocated in the first year.

d the value of the dual life estates as determined by using the dual life estate tables.

e the remaindermen value as determined using dual life tables.