Will, a bachelor, died in 2023. At that time, his sole asset was cash of $15 million. Assume no debts or funeral and administration expenses and no charitable bequests. His gift history was as follows:

a. What was Will’s estate tax base?
b. How would your answer to Part a change if Will made the first gift in 1974 (instead of 1997)?

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Date Amount of Taxable Gifts FMV of Gift Property at Date of Death October 1997 October 2001 $270,000 90,000 $290,000 45,000