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Wendy and Harrison have been married for 55 years and are both in good health. Wendy and Harrison live in a community property state. They have the following children and grandchildren: Children Grandchildren Ali Age 48 3 children Jae Age 35 4 children Constance Age 32 No children Edie Deceased 1 child Ali, a web designer, is married, healthy, and happy. Wendy and Harrison adore Alis husband, Justin, and their three children. Jae, a high net worth investment consultant, was recently divorced and her ex-husband, Randall, has custody of their four children. Wendy and Harrison, never quite cared for Randall, as he always seemed to be quite snooty. Since the divorce, the relationship between Wendy and Randall has been very strained. Since her divorce, Jae has had somewhat of a mid-life crisis. She recently rented a penthouse apartment and bought a new Porsche. Jae has also been dating Chase, a 21-year-old swimsuit model. While Wendy and Harrison are confident that this is only a passing phase, they are concerned about giving any gifts to Jae or her children outright. Constance is a yoga teacher who has never been married and has no children. Constance. Constance has aspirations of going to graduate school to become a entrepreneur and own her own studio but is concerned about taking on debt to pursue additional education. Wendy and Harrison are considering helping Constance pay for graduate school tuition. Edie, Wendy and Harrisons youngest child, was a bit of a wild child. Edie died in a tragic accident in her senior year of college while she was on her way home to tell her parents about a big secret she had been keeping. The summer before, Edie had given birth to a baby girl named Mira. At the time, Edie gave the baby to the babys father, an older married man, although no official adoption was ever transacted. Wendy and Harrison still do not know about Mira. Wendy and Harrison own Hoppy Days Brewing, a popular brewery. Justin, Alis husband, has worked at the business since he was in high school. Justin is now the manager and handles most of the day-to-day functions, with very little input from Wendy and Harrison. Wendy and Harrison would like to reward Justin for all of his hard work by giving Justin and Ali 1/2 of the business and giving the remaining 1/2 of the business to Jae and Constance equally. They do not want Jae and Constance to have any control over the business, just to have an income interest. Alis youngest child, Mari, was born with a serious physical disability. To provide additional support for Mari, Harrison created an irrevocable trust with Mari as the sole beneficiary with a $5,000,000 transfer of separate property in 2013. The trust meets the requirements of Section 2503(c). Harrison and Wendy made the following additional lifetime transfers: In 2010, Harrison gave Ali, Jae, and their spouses $500,000 each of community property. In 2014, Harrison gave Ali, Jae, and their spouses $350,000 each of his separate property. Harrison paid gift tax of $125,500 on these gifts. Harrison and Wendy paid $168,000 in the years 1994-1997 directly to Stanford University for Ali to achieve a degree in Computer Science (assume $42,000 per year). Harrison and Wendy paid $100,000 in the years 2007-2010 directly to UCLA for Jae to achieve a degree in Finance (assume $25,000 per year). Harrison and Wendy paid $34,000 in the years 2010-2013 directly to West Texas A&M University for Constance to achieve a degree in Education (assume $8,500 per year). Harrison and Wendy paid $400,000 to Childrens Hospital for a lung transplant for Mari in 2017. In 2006, Wendy gave Ali $250,000 of her separate property as an anniversary gift. In 2018, Wendy gave each of the grandchildren of which she was aware (assume all grandchildren had been born by 2018) $385,000 of her separate property. Wendy and Harrison have never elected to split gifts of separate property. Harrison and Wendy estimate the following at each of their deaths: The last illness and funeral expenses are expected to be $150,000 per person. Estate administration expenses are estimated at $325,000 per person. Wills Harrison does not have a will. Wendy has an outdated will leaving most of her probate assets to Harrison. Clauses from Wendys Statutory Last Will and Testament I, Wendy, being of sound mind and wishing to make proper disposition of my property in the event of my death, do declare this to be my Last Will and Testament. I revoke all of my prior wills and codicils.

1. I have been married but once, and only to Harrison with whom I am presently living. Out of my marriage to Harrison, four children were born, namely Ali, Jae, Constance, and Edie. I have adopted no one nor has anyone adopted me.

2. I leave my Vintage Bentley and House Boat to my daughter, Jae.

3. I leave the life insurance proceeds on my life to my daughter, Ali.

4. I leave Vacation Home 2 to my daughter, Edie.

5. I leave Auto 2 to the Methodist Church, a qualified charity.

6. I give the residue of my estate to Harrison, my husband.

7. In the event that Harrison predeceases me or fails to survive me for more than six (6) months from the date of my death, I leave any interest of my estate determined to be payable to her to my children, Ali, Jae, Constance, and Edie, in equal and 1/4 shares.

8. In the event that any of the named legatees should predecease me, die within six months from the date of my death, disclaim, or otherwise fail to accept any property bequeathed to him or her, then such interest will pass to the said legatees descendents, otherwise his or her share of all of my property of which I die possessed shall be paid equally among the surviving named legatees.

9. I name my best friend Keith to serve as the executor of my succession with full seizin and without bond.

10. I direct that the expenses of my last illness, funeral, and the administration of my estate shall be paid by my executor as soon as practicable after my death and allocated against the residual estate.

11. Since I have made numerous lifetime gifts to my children, all inheritance, estate, succession, transfer, and other taxes (including interest and penalties thereon) payable by reason of my death shall be allocated to the childrens share, regardless of whether my spouse survives me.