In this question and the succeeding question in this problem (unless the facts indicate to the contrary) assume all parties are U.S citizens. Your clients, a married couple come to you for estate-planning advice. Each spouse has assets worth 12.5 million. They have children but wish to provide for the other in preference to their children. Neither spouse has made any taxable inter vivo gifts. What do you advise them to do? See IRC section 2010.