This is a short answer problem. Please cite the applicable regulation, case, or other authority in support of your analysis. Please note if the answer is yes or no, and could be it depends please state what the issue is and what additional information you would need to answer the problem.

1. The following problems involve a transfer by D to the T trust, trustee, on the following alternative terms. What are the estate tax consequences upon Ds death?

A) Income to D for life, remainder to A and B equally or to their estates.

B) Income to D for life, payable once a year on December 1, remainder to A or As estate, provided that no part of the income accruing between the last December 1 payment and Ds death shall be paid to D, but it shall be added to corpus.

C) Income to D for 15 years, remainder to B or BS estate. D dies after 17 years.

D) Income to D for 15 years, remainder to B or Bs estate. D dies after 17 years.

E) Income to A for life, then to D for life, remainder to B or Bs estate. D predeceases A.

F) Income to W for life, remainder to D if living, otherwise to S if then living. D predeceases W and S.

G) Income to W for life, remainder to D if living, otherwise to S. D predeceases W and S.

H) Income to A for life, provided D does not direct payment to someone else, remainder to B if living, otherwise to As state. D dies during As lifetime.

I) Income to W for life, then to A or B for life as D may direct, remainder to Z. D predeceases W, A and B.

J) Income to A for life, remainder to B of Bs estate. D reserves the right to instruct T to pay income to B. D predeceases A and B.

K) The first $100,000 of income to D, the income to A for life, remainder to B. D dies after payment of $90,000.