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On January 1, 1997, G transfers $100,000 to a trust. The income is payable to G's niece or her estate for ten years, and the

On January 1, 1997, G transfers $100,000 to a trust. The income is payable to G's niece or her estate for ten years, and the corpus reverts to G. What are the gift tax consequences of the transfer assuming a Section 7520 rate of 8%? What are the estate tax consequences if G dies on January 1, 2003? What are the gift and estate tax consequences if the income beneficiary is G's mother?

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