Jesse dies intestate (i.e., without a will) in May 2014. Jesse’s major asset is a tract of land. Under applicable state law, Jesse’s property will pass to Lorena, who is his only child. In December 2014, Lorena disclaims one-half of the property.

In June 2015, Lorena disclaims the other half interest. Under state law, Lorena’s disclaimer results in the property passing to Arnold (Lorena’s only child). The value of the land (in its entirety) is as follows: $2 million in May 2014, $2.1 million in December 2014, and $2.2 million in June 2015. Discuss the transfer tax ramifications of these transactions.