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In 2006, Brett gratuitously transferred the following to his daughter, Savannah: (1) special occasion (e.g., holiday) gifts of cash and outright property, worth in the
In 2006, Brett gratuitously transferred the following to his daughter, Savannah: (1) special occasion (e.g., holiday) gifts of cash and outright property, worth in the aggregate $1,000, (2) a whole life policy, and all associated rights and powers under the policy, on Brett's life, with a face value of $100,000 that Brett purchased 10 years ago, and (3) a diamond necklace. At the time of the transfers, the interpolated terminal reserve value (i.e. fair market value) of the insurance policy was $7,000 and the fair market value of the diamond necklace was $5,000. Upon receiving the insurance policy, Savannah irrevocably named herself or her estate as beneficiary under the policy. In January 2008, Brett died. Which of the following is the best description of the tax consequences based on these facts alone? Brett made a taxable gift in 2006 and there is no inclusion in Brett's gross estate B. Brett made a taxable gift in 2006 and there is inclusion in Brett's gross estate C. Brett made no taxable gift in 2006 and there is no inclusion in Brett's gross estate D. Brett made no taxable gift in 2006 and there is inclusion in Brett's gross estate
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