Diego is a single individual who owns a life insurance policy worth $$2\mathrm{.}5$ million that will be worth $$8$ million upon his death. This year

Diego transferred the policy and all incidents of ownership to an irrevocable trust that pays income annually to Diego's two children for

$15$ years and then distributes the corpus to the children in equal shares. Assume that Diego has made only one prior taxable gift of $$15$

million in January of $2018.($Refer to Exhibit $25-1$ and Exhibit $25-2.)$

Required:

a$.$ Calculate the amount of gift tax due $($if any$)$ on the transfer of the insurance policy.

b$.$ Diego died unexpectedly this year after transferring the policy. At the time of death, Diego's probate estate was $$25$ million, to be

divided in equal shares between Diego's two children. Calculate the amount of cumulative taxable transfers for estate tax purposes.

Note: For all requirements, enter your answers in dollars and not in millions of dollars.