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Francis makes a gift of income producing property to a trust for the benefit of his three children, Able, Bree and Cheerful. At the time

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Francis makes a gift of income producing property to a trust for the benefit of his three children, Able, Bree and Cheerful. At the time of the gift the trust is valued at $800,000. ?The terms of the trust require that all income is to be distributed equally to each child, annually for ten years. After ten years the trust corpus is to be distributed equally to the three children. Francis retains the right to divest Able and Bree of all income each year and give it to Cheerful. The value of each income interest is $200,000. ?The value of the entire trust when Francis dies is $1,000,000. ?How much, if any, is required to be included in the gross estate of Francis upon his death?
$0.
$400,000.
$600,000.
$800,000
$1,000,000.
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