Question: Fred is very generous. During the current year he made gifts as described below. In the case of each gift, state whether any portion of

Fred is very generous. During the current year he made gifts as described below. In the case of each gift, state whether any portion of the gift constitutes a present interest for purposes of ยง 2503(b), thereby qualifying for the annual per donee exclusion. (a) Fred gave $13,000 in cash to Artemis. (b) Fred gave to Betty an insurance policy on Fred's life. The amount payable upon Fred's death is $100,000. Betty has an insurable interest in Fred's life, and at the time of the gift the policy had a market value of $5,000. (c) Fred paid the annual premium of $3,000 under a $100,000 insurance policy on Fred's life owned by Carl, who has an insurable interest in Fred's life. (d) Fred contributed $39,000 to Powell Corporation, a manufacturing business. The stock of Powell Corporation is owned in equal one-third amounts by Dalton, Dewey, and Doris. Fred has no interest in the corporation.

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