Question: 1 . In 2 0 2 0 , taxpayer J created an irrevocable trust and transferred $ 1 0 0 , 0 0 0 to

1. In 2020, taxpayer J created an irrevocable trust and transferred $100,000 to it. The terms of the trust are that the trust can purchase life insurance on Js life, but cannot make any distributions until Js death, at which point, the trust may make loans to Js spouse and must distribute all assets to Js three children. J died in 2025 owning $20,000,000 in Js bank account and no other assets. The life insurance owned by the trust also collected a death benefit of $10,000,000 on Js death and distributed the assets to Js children. Js Will stated that $5,000,000 was to be distributed to Js spouse and the remaining $15,000,000 to Js children. J had no other transactions during Js life.

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