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Hugh and Wilma Brown are married to each other throughout 2022. Hugh made no taxable gifts in earlier periods. Wilmas previous taxable gifts were $300,000

Hugh and Wilma Brown are married to each other throughout 2022. Hugh made no taxable gifts in earlier periods. Wilmas previous taxable gifts were $300,000 in 1975 and $200,000 in 1988.

In August 2022, Wilma makes the following gratuitous transfers:

  • $80,000 in cash to son Billy
  • $40,000 in jewelry to daughter Betsy (basis to donor, $18,000)
  • $34,000 in medical expense payments to Downtown Infirmary for medical care of grandson Tim
  • Remainder interest in vacation cabin to friend Ruth Cain. Wilma (age 60) retains a life estate. The vacation cabin is valued at $100,000 (basis to donor, $15,000).
  • $600,000 of stocks (basis to donor, $480,000) to a bank in trust with all of the income payable semiannually to husband Hugh (age 72) for life and remainder payable at Hughs death to Jeff Bass, Wilmas younger brother, or Jeffs estate. Wilma wants to elect the marital deduction.

In 2022, Hughs only gifts were:

  • $100,000 of stock to State University (basis to donor, $32,000)
  • $600,000 of land to daughter Betsy (basis to donor, $112,000)

Assume theapplicable interest ratefor valuing lifeestates and remaindersis 4%. The actuarial tables applicable are those in effect in 2022.

Please help Calculate the gift tax liability for Wilma Brown, assuming that she and her husband Hugh decide to elect gift splitting.

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