In year 1, H creates an irrevocable trust of $100,000 with income to W for life, remainder to his Son. H makes a QTIP election. In year 3, when the trust corpus is still worth $100,000, W, age 65, gifts her entire income interest to Daughter. W is in the 40% gift tax bracket and has used up her Applicable Exclusion Amount. What is the value of the gift imputed to W assuming the § 7520 interest rate is 2%?