Ayana is the owner of a business with a recently appraised net worth of 25 million dollars. The business is growing at the rate of 4% per year (value will be increasing by one million dollars in the next year). Ayanas basis in this business is $3 million.

If on day one when the business was worth $25 million dollars, Ayana sold the entire business to her children in exchange for $1,000 cash and a promissory note for $24,999,000 would the sale produce any federal gift tax liability?