Ira has a gross estate of $12 million and his second wife Elizabeth has an estate valued at $2 million. Ira provided his attorney with the following objectives: He wants to minimize the couples estate tax liability for their combined taxable estates. He wants Elizabeth to receive all income annually from a trust that will provide him with a marital deduction in his estate. The trust corpus will be distributed to Iras two children at Elizabeths death. He wants Elizabeth to receive income from another trust, if needed, but Ira does not want the assets in this trust included in her gross estate. He also wants his children to be beneficiaries of this trust. Which marital planning technique would not meet Iras objectives?

Select one:

a. The couple should equalize their estates by having Ira gift $5 million to Elizabeth.

b. Ira should establish a bypass trust funded with the full exemption equivalent amount.

c. Ira should establish a trust that his executor will elect to qualify for QTIP treatment at his death.

d. Ira should establish a power of appointment trust that provides Elizabeth with access to all income and corpus.