Under his will, Steve creates a trust, life estate to his daughter Regina and remainder to Allen (his grandson) upon Reginas death. Steve hopes to save on estate taxes with this strategy. Specifically, he is hoping that, by establishing this trust arrangement, Regina can avoid Federal estate taxation. Steve also directly gives an asset worth $3,000,000 to his granddaughter Amber in order to avoid two levels of Federal estate taxes. Do you see a problem with Steves plan?