Arthur Zolnick died at age 84 on June 7, 2016. In March 2008, he transferred $4 million of stock to a charitable remainder annuity trust (CRAT) from which he named himself to receive $200,000 per year for life. He designated a charitable organization to receive the remainder interest after his death and appointed his nephew Luther as trustee. Luther never distributed cash to Arthur because Arthur indicated he had no need for additional funds that “would just add to my gross estate.” At Arthur’s date of death, the value of the assets in the CRAT had risen to $8.3 million. Another firm prepared Arthur’s estate tax return, on which it claimed a charitable contribution deduction for the CRAT. The IRS proposed disallowing the deduction. Arthur’s executor has engaged your firm to address whether a charitable contribution deduction should be available.