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Ryan placed $365,000 in trust with income to Stephen for his life and the remainder to Kayla (or her estate). At the time of the

Ryan placed $365,000 in trust with income to Stephen for his life and the remainder to Kayla (or her estate). At the time of the gift, given the prevailing interest rate, Stephen's life estate was valued at $196,000 and the remainder at $169,000. What is the amount, if any, of Ryan's taxable gifts?

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