D died in Year 1 with the following: Bank Account in D's name A lottery ticket...
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D died in Year 1 with the following: Bank Account in D's name A lottery ticket which entitled the ticket owner to receive $1 million a year for 20 years. D purchased the ticket 5 years ago and there were 15 years of payment left. The right to receive income for life from a trust established by D's spouse as a QTIP trust. Remainder to D's children. The right to receive income for life from a trust established by D's uncle with remainder to D's children. $3,000,000 FMV $12,000,000 FMV of the 15 payments. $5,000,000 (FMV of Trust) $4,000,000 (FMV of Trust) $1,000,000 (FMV of the possibility of receiving the $2,000,000) The possibility of receiving $2,000,000 from D's employer for work performed prior to death, if certain financial benchmarks were satisfied. The right to receive income for 10 more years (until Year 10) from a Trust with $8,000,000 of assets, which D established 5 years ago. The remainder (value of trust after 10 years) to D's children. What is D's Gross Estate (based solely on the above)? $4,000,000 (FMV of the income interest for 10 years) .D created an irrevocable trust on January 1, 2020.D transferred assets worth $2,000,000 to the trust. The terms of the trust were that D would receive $500,000 yearly payment for 4 years.At the end of 4 years, the trust would terminate and the remainder would be distributed to D's child. Assuming the interest rate (§7520) is 5% at all times. a. Has D made a taxable gift? If so, in what amount? b. Would your answer to (a) change, if in fact the FMV of the trust were $1,500,000 at the end of 4 years? D died in Year 1 with the following: Bank Account in D's name A lottery ticket which entitled the ticket owner to receive $1 million a year for 20 years. D purchased the ticket 5 years ago and there were 15 years of payment left. The right to receive income for life from a trust established by D's spouse as a QTIP trust. Remainder to D's children. The right to receive income for life from a trust established by D's uncle with remainder to D's children. $3,000,000 FMV $12,000,000 FMV of the 15 payments. $5,000,000 (FMV of Trust) $4,000,000 (FMV of Trust) $1,000,000 (FMV of the possibility of receiving the $2,000,000) The possibility of receiving $2,000,000 from D's employer for work performed prior to death, if certain financial benchmarks were satisfied. The right to receive income for 10 more years (until Year 10) from a Trust with $8,000,000 of assets, which D established 5 years ago. The remainder (value of trust after 10 years) to D's children. What is D's Gross Estate (based solely on the above)? $4,000,000 (FMV of the income interest for 10 years) .D created an irrevocable trust on January 1, 2020.D transferred assets worth $2,000,000 to the trust. The terms of the trust were that D would receive $500,000 yearly payment for 4 years.At the end of 4 years, the trust would terminate and the remainder would be distributed to D's child. Assuming the interest rate (§7520) is 5% at all times. a. Has D made a taxable gift? If so, in what amount? b. Would your answer to (a) change, if in fact the FMV of the trust were $1,500,000 at the end of 4 years?
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