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On January 1, Year 1, Individual A, transferred $10,000,000 to an irrevocable trust. The terms of the trust were that the trustee was required to

On January 1, Year 1, Individual A, transferred $10,000,000 to an irrevocable trust. The terms of the trust were that the trustee was required to distribute trust income to individuals B and C, or their estates, in equal shares during As life, and at As death would distribute the remainder equally to B and C or their estates. A however, retained the power to distribute any amount of trust principal to either B or C in As discretion. T distributed $15,000 of trust income to each of B and C or their estates for 12 years (when A died). In addition, in Year 5 A directed a distribution of $200,000 cash to A and in Year 7 A directed a distribution of $400,000 to C. B died in year 9. In year 12 when A died, the trust was valued at $16,000,000 and 12 was distributed to A and 12 to Bs estate. A made no other transfers during life. Which of the following statement is correct?

  1. A has made a complete gift of just the remainder interest in Year 1

  2. A has made a complete gift of $10,000,000 in Year 1

  3. A's estate tax due will be $1,905,800 (assuming A had no assets or transfers other than the ones listed here)

  4. A has made a complete gift in Year 9

  5. None of a-d are correct

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