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In 2002, H made a gift to his child, C, in the amount of $2,222,000. Hs wife, W, consented to split-gift treatment of the gift,

  1. In 2002, H made a gift to his child, C, in the amount of $2,222,000. Hs wife, W, consented to split-gift treatment of the gift, and H paid all the taxes payable resulting from the gift.
    1. What would be the estate tax consequences if h died in Year 2006, assuming his taxable estate would otherwise be $1,750,000, which he left entirely to C?
    2. What would be the result if H died in 2004?
    3. Assume that W died in 2004 with a taxable estate of $1,250,000. She left her entire estate to C. What would be her estate tax, assuming that H paid all gift taxes on the split gift?
    4. What would be the tax result in (b) and (c) if at the time of the gift in 2002, W paid the $41,000 gift tax liability out of her assets?
    5. What would be the tax result in (b) and (c) if at the time of the gift in 2002, W had paid both her gift tax liability and Hs gift tax liability out of her own assets?

Tax Rate is irrelevant.

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