Question
T, who never married nor made any prior inter vivos gifts, made taxable gifts for $6 million in 2013. T dies in the current year,
T, who never married nor made any prior inter vivos gifts, made taxable gifts for $6 million in 2013. T dies in the current year, leaving a taxable estate of $5 million. In 2002, G created a trust, the income to be paid to Gs child T (our same good old T) for life, remainder to Ts child R. (Dont worry about G who is not a part of the problem.) At Ts death in the current year, the remainder of interest of the trust corpus, valued at $4 million, was paid over to R.
(a) Using proper rate computation provided by Section 2502 and considering the Section 2505 applicable credit amount, disregarding inflation adjustments to the applicable exclusion amount, what is Ts gift tax liability for 2013?
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