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Devon creates an irrevocable trust by transferring $2,000,000 to Friendly National Bank as Trustee to pay the income to Devon during his life and the

Devon creates an irrevocable trust by transferring $2,000,000 to Friendly National Bank as Trustee to pay the income to Devon during his life and the remainder to Amanda. Devon and Amanda are unrelated. When Devon is 75 years old, he gifts the income interest to his friend, Bruce. Devon dies two years after the gift. What are the gift and estate tax consequences?

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