Holly Miller is in poor health and would like to make a gift to her nephew, Todd. Holly's main goal is to reduce administrative expenses and taxes on her estate. She also would like to keep both her and Todd's income tax liability as low as possible. Her will leaves everything to Todd when she dies. Todd does quite well financially, but Holly would like to give him something while she is alive.

Based on her objectives, which one of the following transfers to Todd would be the most appropriate?

A)

Giving up her retained income interest in an irrevocable trust and accelerating Todds remainder interest; the trust corpus is valued at $39,000

B)

Transferring a stock portfolio worth $45,000 to Todd; her basis in the portfolio is $5,000

C)

Assigning to Todd all incidents of ownership in a life insurance policy that Holly currently owns on a friends life; the policy names Todd as the primary beneficiary of a $100,000 death benefit; replacement cost of the policy is $44,000

D)

Making Todd a joint tenant with right of survivorship in a one-acre tract of land she owns in a neighboring state; the land is valued at $35,000