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Tony and Gail are married with 5 children. Tony has also made the following gifts: On 2 / 2 / 0 9 $ 2 0

Tony and Gail are married with 5 children. Tony has also made the following gifts: On 2/2/09 $200,000 to each of his children of his separate property assuming the annual exclusion was 13k. in 2009 the gift tax equivalent was 1m. Tonly also gave on 1/1/2012 $100,000 to each of his children. the annual exlusion at the time was 13k. the gift tax credit equivalent was 5,120,000. Gail has never made any taxable gifts and has not agreed to split any of Tony\'s separate property gifts. Tonys grandson Philip, Berties youngest child, was born with a serious physical disability. To provide additional support for Philip, Tony created an irrevocable trust with a $2,500,000 transfer on January 1,2008. The trust met the requirements of IRC Section 2503(b). At the time of the transfer (2008), the GST exemption was $2,000,000, the GST rate was 45 percent, and the annual exclusion was $12,000. In 2008, the gift tax credit equivalent was $1,000,000.
Assuming the facts given and that Tony died on July 31,2022, answer the following questions. Use the gift and estate rates and exclusions at the time of any transfer. Use 2022 exclusions, credits, and tax rate for the estate tax. 1. Calculate the gift tax and GSTT consequences of the gift to Philip made on January 1,2008.

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