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Bill is establishing an irrevocable trust in the amount of $3.5 million in stock for the benefit of his daughter, who is an adult. The

Bill is establishing an irrevocable trust in the amount of $3.5 million in stock for the benefit of his daughter, who is an adult. The terms of the trust provide that Bill's daughter is to receive all income for life and, upon her death, the trust corpus is to be subject to a testamentary general power of appointment exercisable in the daughter's Last Will and Testament. Which answer option is incorrect? a. If Bill should die next year, the value of the irrevocable trust at that time will be excluded from his federal gross estate. b. The creation of the irrevocable trust will constitute an adjusted taxable gift for federal gift tax purposes by Bill. c. The irrevocable trust will be treated as a simple-type trust for federal fiduciary income tax purposes. d. Bill must allocate GST Exemption against this trust on Form 709, Federal Gift Tax Return, to protect it from imposition of the GST Tax in the event Bill's daughter dies prematurely.

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