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On January 2 of this year, Nick creates an irrevocable $10,000,000 trust. Under the terms of the trust, the trustee is to pay $75,000 of

On January 2 of this year, Nick creates an irrevocable $10,000,000 trust. Under the terms of the trust, the trustee is to pay $75,000 of trust income semiannually to his wife, Loretta, for the rest of her life. The trust constitutes Qualified Terminable Interest Property (“QTIP”). Upon Loretta’s death, the trust assets are to be distributed to Nick’s son and daughter-in-law, Sam and Diane. Nick died suddenly and unexpectedly on December 10, 2022, when the trust was valued at $14,000,000. Loretta, Sam, and Diane survive Nick.

How much, if any, can Nick’s estate claim for the Section 2056(b)(7) martial deduction?

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