Robert $(65)$ and Rachel $(50)$ Green live in Springfield, Missouri, have three children, Nicole $(23),$ Ryan $(21)$ and Danielle $(15)$ and six grandchildren. Rachel has a daughter, Paula $(30),$ from a previous marriage. Robert, a veterinarian, owns an animal hospital, Green Animal Care LLC$,$ with $25$ employees. Rachel is a CPA at an international accounting firm. Robert and Rachel own the following assets.

ASSET $ FMV

on DOD OWNERSHIP

Life Insurance on Robert $32,650$ ILIT$*$

Life Insurance on Rachel $70,400$ Robert; Danielle is beneficiary of $$350,000$ death benefit

$401$k $1,500,000$ Robert; Rachel is beneficiary

IRA $800,000$ Robert; Rachel is beneficiary

Cash $675,000$ Robert

Mutual Funds $3,500,000$ Robert & Rachel, joint tenants

House and $200$ acres $19,525,000$ Tenants by entirety

Car $1148,000$ Rachel; TOD to Ryan

Car $274,250$ Robert; TOD Robert$$s trust

Vacation Home in Key West $4,842,000$ Robert as trustee of his revocable trust

$1200$ shares Pfizer stock Market Robert as trustee of his revocable trust

Green Animal Care LLC $11,377,480$ Robert

$*$Robert was the original owner of the policy. He transferred the policy to the ILIT last year. There was no taxable gift when the ILIT was funded. The death benefit is $$2,900,000$ and all four children are the beneficiaries of the trust.

Robert is the beneficiary of the First Family Trust created by his parents in $2008.$ Robert has the right to withdraw $3\%$ of the trust each year until December $31.$ The balance of the trust each year is $$9,475,000.$ Robert exercised his withdrawal right every year until $2017.$ He did not exercise his withdrawal right between $2017$ and this year.

Robert gave $$38,000$ cash to each of his three children in $2022.$ Rachel did not split the gifts with him and those were the only gifts he made that year. He paid $$16,150$ in gift tax on the gifts.

In $2021,$ Robert gave Paula his father$$s coin collection. The FMV on the date of the gift was $$850,000.$ Robert paid gift tax of $$243,300.$ Rachel did not split the gift and this was the only gift to Paula that year.

In $2022,$ Robert gave $1000$ shares of O$$Reilly Auto stock to the Humane Society $(501($c$)(3)$ charity$).$ The stock was worth $$525/$share on the date of the gift. Robert$$s basis in the stock was $$32\mathrm{.}50/$share$.$

$$

Robert died on Sunday, April $9,2023.$ Trading information for Pfizer in $2023$:

PFE Open High Low Close

Apr. $654\mathrm{.}8555\mathrm{.}5854\mathrm{.}4655\mathrm{.}17$

Apr. $752\mathrm{.}5055\mathrm{.}4052\mathrm{.}5055\mathrm{.}16$

Apr. $1053\mathrm{.}3053\mathrm{.}9352\mathrm{.}6553\mathrm{.}11$

Apr. $1155\mathrm{.}4656\mathrm{.}3253\mathrm{.}8053\mathrm{.}93$

$1.$ In the chart below, indicate which assets are included in Robert$$s gross estate, the amount included, and which Internal Revenue Code section causes the inclusion? $($You may need to add rows for additional assets.$)6$ points

ASSET $ Included in Gross Estate $$ IRC

Life Insurance on Robert

Life Insurance on Rachel

$401$k

IRA

Cash

Mutual Funds

House and $200$ acres

Car $1$

Car $2$

Vacation Home in Key West

$1200$ shares Pfizer stock

Green Animal Care LLC

Total Gross Estate