S transfers $100,000 to an irrevocable trust, the income of which is to be shared equally by

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S transfers $100,000 to an irrevocable trust, the income of which is to be shared equally by A and B for 10 years, remainder to C. How many annual exclusions are available for S, and in what amount if the § 7520 rate is 2%? See Treas. Reg. § 25.2503-3(a).