Consider the following as to how each would effect the estate tax return for Allen's estate:

In 2020, Allen established an irrevocable trust which he funded with $500,000. The terms of the trust provided that the income was to be paid to his sister Amy for her life, then to Allen for his life if he survived Amy, and upon the death of the survivor of Allen and Amy, the principal was to be distributed to Amy's children equally. Amy survived Allen. According to the IRC valuation tables, at the time of Allen's death, Amy's income interest was worth $350,000, and the remainder interest is worth $200,000.