Doris has $100,000 of GST exemption left to use. In one year she makes the following two gifts:

• She writes a $100,000 check to her granddaughter, Ally.
• She also uses $100,000 to fund a trust for the benefit of her son, Ray. Upon Rays death, the trust will be distributed to his son, Michael.

Doris decides not to proactively allocate GST on the 709 and lets the default allocation rules govern.

Which of the following is true?

a. $50,000 of the GST exemption will be allocated to Allys gift and $50,000 will be allocated to Rays trust.

b. All of the GST exemption will be applied to Allys gift as a direct skip, and none will be allocated to Rays trust.

c. All of the GST exemption will be applied to Rays trust and none will be allocated to Allys gift.

d. Doris missed the filing deadline so none of the GST exemption will be allocated to either transaction.