When Sam died, his property was placed in trust, with his son David and David's daughter Carole

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When Sam died, his property was placed in trust, with his son David and David's daughter Carole eligible to receive principal and income at the trustee's discretion. When the property was placed in trust, its value was $5 million, and the GST exemption was not allocated to this trust. Carole received a distribution of $8 million when the trust's value totaled $10 million. The appraisal to value trust assets cost $40,000 and was paid by the trust. What is the taxable amount of the generation-skipping transfer, and who is responsible for the tax payment? Taxable Amount Taxpayer

A. Taxable Amount $8,000,000 Taxpayer David

B. Taxable Amount $7,960,000 Taxpayer Carole

C. Taxable Amount $5,040,000 Taxpayer David

D. Taxable Amount $7,960,000 Taxpayer Trust