In 2004, Amy made $5 million of taxable gifts, none of which were included in her gross estate. In 2021, Amy died with a taxable estate of $8 million. The property Amy gave away in 2004 appreciated to $7 million in value by her date of death. In 2005, Amy gave stock valued at $8,000 to one of her children. Amy made no taxable gift and incurred no transfer tax on the 2005 transaction. The stock had appreciated to $70,000 when Amy died. Amy's estate tax base is calculated as