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Steve wants to give his minor son, Andy, an interest in an S corporation. Steve is considering making an outright gift of the stock or

Steve wants to give his minor son, Andy, an interest in an S corporation. Steve is considering making an outright gift of the stock or creating a Section 2503(c) or 2503(b) trust for Andy. Either Andy or the trust is to be a shareholder in the S corporation. Under which circumstances would the stock or the trust not be includable in Andy's estate for estate tax purposes if he died?

a)

Andy owns the stock outright.

b)

The trust is a QSST and the trust is payable to Andy's estate at his death.

c)

The trust is a Section 678 trust and Andy has a general power of appointment.

d)

The trust is a QSST and Andy has only an income interest which ends before his death.

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