On February 15, 2023, Donald establishes an irrevocable trust, which he funds with $300,000, and makes Daisy his trustee. Under the terms of the trust, Donald is the income beneficiary of the trust and has the right to receive all of the income during his lifetime. Daisy may invade the trust corpus to pay for Donald's health, education, maintenance, and support. The residuary beneficiaries are Donald's nephews: Huey, Dewey, and Louie. The value of the gift to Huey that Donald reports and pays gift tax on is $83,000 ($100,000 - the $17,000 per donee annual exclusion)