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13 at 10 p.m. Please type your answers to the questions below. Be thorough in explaining your answers, and cite the proper Internal Revenue Code section or Treasury Regulation section that supports your answer. 1. Six years ago, Carolyn purchased from an insurance company a $300,000 policy on her life payable to her son, Ed, who her will also designated as the executor of her estate. One month after taking out the policy Carolyn irrevocably assigned all incidents of ownership in the policy to Ed. Carolyn annually gave $17,000 to Ed who, after the first year paid the $3,000 annual premium on the policy. At Carolyn's death $300,000 was paid to Ed by the insurance company. What are the estate tax consequences? 2. Susan last year acquired a $500,000 policy on the life of her husband, Tom, payable to their son, Steve. Until Tom's death last month, Susan continued to hold all incidents of ownership in the policy which included the ability to change beneficiaries. What are the estate and gift tax consequences of the above to Susan, Steve and Tom's estate? 3. In the prior problem assume that two months after acquiring the policy Susan assigned all incidents of ownership in the policy to Steve. 4. In problem (2) assume that Steve rather than Susan had acquired the policy on his father's life. 5. Ten years ago, David purchased a $500,000 life insurance policy on his life, and irrevocably designated his children, Rebecca and Erica, as the beneficiaries. David retained the right to take out loans against the cash surrender value of the policy. The insurance policy had a $100,000 cash surrender value. Three years ago, David was injured in a car accident. He had several medical bills not covered by health insurance. Since David did not have enough savings to cover the medical costs, he took out a $75,000 loan against the insurance policy. Last month, David died unexpectedly. David had repaid the loan before his death. The insurance company paid the $500,000 insurance proceeds to Rebeca and Erica. What are the estate tax consequences? 6. Patricia had held all incidents of ownership on a $500,000 policy on her life payable to her daughter, Maria. On advice from her attorney, Patricia, six years ago, assigned all incidents of ownership on the policy to an irrevocable trust for the benefit of Maria with her attorney serving as trustee. On Patricia's death earlier this month $500,000 was paid to Maria. What are the estate tax consequences? 7. Steve and Emma, who are married, each took out a $300,000 policy on the other's life payable equally to their children, Andrew and Gabriella. Until Steve's death six weeks ago they each had retained all incidents of ownership in the policies acquired by them, including the ability to change beneficiaries. What are the gift and estate tax consequences of the above? 8. Fatima made a gift of stock to Yousef 18 months ago. At the time of the gift, the stock was worth $75,000, and Fatima paid $16,900 of the gift tax on the transaction. At Fatima's death 4 months ago, the stock was worth $115,000. What amount is included in Fatima's estate and why? 9. Nine years ago, Mordechi established a trust under which he retained income for his life with remainder to his daughter Esther. Upon discovering that he had a terminal illness, Mordechi transferred his life interest to Esther. The trust's sole asset then consisted of an apartment building. At the time of the transfer, Mordechi's life estate was worth $150,000, and Mordechi's remainder interest was worth $100,000. Mordechi paid $50,000 in gift tax on the transfer. At Mordechi's death 17 months later, the value of the trust's assets (the same apartment building) was $500,000. What amount is includible in Mordechi's estate and why? 10. Vira was sole shareholder of Koltana, Inc., which held a $1,000,000 term insurance policy on Vira's life payable to her son Ivan. Two years ago, when the stock of Koltana was worth $4,000,000, Vira gave the stock to Ivan and paid of gift tax of $1,545,800 on the transfer. At Vira's death last month, Koltana (exclusive of the insurance policy) was worth $5,000,000. Shortly after Vira's death, Beclair Insurance paid Ivan the $1,000,000 policy proceeds. What amount is includible in Vira's estate and whv