How many annual exclusions, if any, would you, as a financial advisor advise client to take?

1. How many annual exclusions, if any, do you believe the IRS will allow A to take (assuming the IRS reviews this trust)?
2. IF TAM 9628004 were valid law, how many annual exclusions do you believe A could take?
3. A creates an irrevocable trust in 2020. The terms of the trust are that A's children will receive trust income during A's life, and at A's death, trust principal will be distributed to A's then living children, or to the then living children of any of A's children who are then deceased (i.e. A's grandchildren). The trust gives A's three children, A's 7 grandchildren and A's 5 nieces and nephews, the power to withdraw $10,000 each year. Such withdrawal power lapses at the end of each year. A contributed $1,000,0000 to the trust in 2020 and will contribute $150,000 to the trust each year thereafter.
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