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Luke Adams transfers $ 8 0 0 , 0 0 0 to an irrevocable trust. Under the terms of the transfer, Luke s friend Jason

Luke Adams transfers $800,000 to an irrevocable trust. Under the terms of the transfer, Lukes friend Jason (currently age 35) will receive an income interest for the remainder of his life, and then the corpus of the trust (the remainder) passes to Jennifer who is not related to Luke. At the time of the transfer, 120 percent of the AFR rate was 7.0 percent, yielding a present value factor of .09155.
a. What are the gift tax consequences associated with the transfer?
b. Now assume that Luke retains an income interest in the property for himself, rather than for Jason. Luke is currently 35 years old. What are the gift tax and estate tax consequences associated with the transfer?

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