If Mel were to die December 31, 2022, what would his federal estate tax liability be?

(Utilizing the format shown in the last picture)

Mel, age 62, and Oksana, age 23, have been dating for about a year and a half. Mel and OKsana met when Mel was on a vacation in south of France. Oksana was a beautiful Russian artist selling paintings at the market by Mel's hotel. After a month-long romance, Mel asked Oksana to return to the United States with him. Although not a United States citizen, she has maintained residence in the United States for 15 months. While they have no current plans to marry, they recently found out that Oksana is expecting her first child. Although no paternity tests have been conducted, both Mel and Oksana are confident the child is Mel's. When they found out Oksana was pregnant, Oksana moved into the 4-bedroom home Mel owns so they could prepare for the baby, whom they plan to name Lucia. To prove to Oksana that he was serious about them being a family, Mel gave OKsana $10,000,000 in a money market account in January 2019. The money market account is the only asset Oksana owns. Mel also purchased a $15,000,000 life insurance policy on his life and named Oksana as the beneficiary. Mel was previously married and has two children from that marriage, Hanna, age 38, and Christian, age 33 . Both kids are happily married and have children of their own. Hanna has two children, Edward, age 3, and William, age 13. Christian was unable to have children of his own; therefore, he adopted a little boy, Milo, age 2, from Russia last year. Mel and his first wife, Robyn, have been divorced for ten years and are not on speaking terms. After their marriage, Mel was required to pay Robyn alimony in the amount of $18,000 per month. When the court order expired at the end of 2015, Mel felt bad so he continues to give Robyn $18,000 per month on the first of each month. Although Mel has high blood pressure, he is otherwise healthy. Oksana has never been married. She is in excellent health and learned just a few days ago that they are having a baby girl, who is expected to be healthy. Mel is retired and owns Braveheart, a local bar \& grill, while Oksana is currently unemployed. Mel and Oksana live in a community property state. Mel's mother, Anne, also lives with him. Anne is 82 and in faling health. She was recently diagnosed with Parkinson's disease. While she is unable to feed or bathe herself, she is expected to live for several more years. Anne has already spent all of her retirement assets and relies exclusively on Social Security. The only substantial asset she owns is a life insurance policy covering her life. The policy has a $100,000 death benefit. The policy does not have a named beneficiary. For estate planning purposes, Mel estimates the following expenses at his death: 1. The last lilness and funeral expenses are expected to be $100,000. 2. Estate administration expenses are estimated at $180,000. 3. Funeral expenses are expected to be $120.000. GIFTS TO CHILDREN in 2018 Mel made the following gifts to his children during 2018: - Mel gave $200,000 of separate property to Hanna. - Mel paid $308,000 to Stanford for Christian's undergraduate tuition. - Mel gave Christian a Range Rover valued at $128,500 to celebrate his success at Stanford. - Mel also gave each grandchild $10,000 each. GIFTS TO GRANDCHILDREN in 2019 Mel made the following gifts to his grandchildren during 2019: - Seeing how Mel's mom outlived her assets, Mel is afraid his grandchildren may have the same fate. To assist them with their retirement income, Mel decided to establish a trust for the grandchildren. The trust is an irrevocable trust and he funded it in the current year with $950,000. The trust will accumulate income until each grandchild reaches age 50. When a grandchild reaches age 50 , he/she will begin receiving an annuity for their life. When all of the grandchildren die, if there is any remaining assets then the trustee may distribute those assets to a charitable organization of his choosing. - Mel sent a check in the amount of $18,000 directly to William's private school to pay her tuition. - Mel also gave each grandchild $10,000 each. Assume Mel paid gift tax of $3,820,000 in 2017 for taxable gifts in the amount of $15,000,000 made in 2016. These were his first taxable gifts. Notes to Financial Statements: 1. Assets are stated at fair market value (rounded to even dollars), 2. Liabilities are stated at principal only (rounded to even dollars). 3. Braveheart was valued last week for insurance purposes. The valuation includes $1,000,000 for the land and $850,000 for the business. 4. The qualified plan has Robyn listed as the designated beneficiary. The Investment Portfolio is a Transfer on Death (TOD) account with Hanna and Christian as the listed beneficiaries. 5. The adjusted basis of the primary residence is $4,000,000. 6. Mel received the vacation property as an inter vivos gift from his grandfather, Otto. Otto purchased the vacation property for $10,000 and the FMV of the property at the date of transfer to Mel was $30,000. The FMV when Otto died was $90,000. The annual exclusion did not apply to the transfer and the gift tax paid was $15,400. 7. The yacht is owned joint tenancy with rights of survivorship with Robyn. They each contributed 50% of the purchase price. The Statement of Financial Position only reflects Mel's interest. 8. Mel's state does not have any statutes that invalidate bequests or beneficiary designations to prior spouses. 9. This statement is prepared after all the gifts were made, including the one to Oksana, and the gift tax has been paid for the 2015 gifts. Gross Estate Less Deductions: Last Medical Expenses Administrative Costs Funeral Expenses Debis of the Decedent Losses During the Administration of the Estate Equals: Adjusted Gross Estate Less: Unlimited Charitable Deduction Less: Unlimited Marital Deduction Less: State Death Tax Deduction Equals: Taxable Estate Add: Previous Taxable Gifts (post 1976) Equals: Tentarive Tax Base Tentative Tax Less: Allowable Credits Credit for Previous Gift Tax Paid Applicable Estate Tax Credit (Unified Credit) Credit for Tax Paid on Prior Transfers Foreign Death Tax Credit Equals: Federal Estate Tax Liability