Barry is the son of Jack, and the father of Joan and Cheryl. In 1984, Jack established an irrevocable trust with cash in the amount of $450,000 for the benefit of Barry and his issue per stirpes. The Trustee is authorized to pay principal and income to any trust beneficiary, to the exclusion of other trust beneficiaries, in its sole and absolute discretion. Today, the trust is worth $2.35 million, and Cheryl requests a discretionary distribution of $35,000 to buy a new car. Which of the following statements is correct regarding this fact pattern? a. Assuming the discretionary distribution is approved, Cheryl will be subject to Generation Skipping Transfer Tax on the distribution as a taxable termination. b. If Jack were to die today, the full value of the irrevocable trust will be included in his federal gross estate. c. Assuming the discretionary distribution is approved, Cheryl will pay income tax on the distribution, subject to the trust's DNI. d. Assuming the discretionary distribution is approved, the Trustee will also need to make an equalizing distribution to Joan in the amount of $35,000.