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Zeke was predeceased by his wife, Zelda. Zelda, a former circus star, met her untimely end while practicing her high dive act. She was in

  1. Zeke was predeceased by his wife, Zelda. Zelda, a former circus star, met her untimely end while practicing her high dive act. She was in the middle of her dive when she saw to her horror that no one remembered to fill her 9000-gallon water tank. Upon Zelda’s death, her executor elected Qualified Terminable Interest Property (“QTIP”) treatment for property that passed from Zelda to a $1,782,000 trust for Zeke’s benefit. The qualifying trust provided Zeke with quarterly income distributions for the rest of Zeke’s life, after which the trust assets will go to heir daughter. At Zelda’s death, the trust assets were worth $1,550,000, When Zeke died 15 years later in 2022, the assets of the trust were worth $4,460,540. 

  2. How much of the trust will be includable in Zeke’s gross estate?

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