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Estate and gift taxation
Elena was the income beneficiary created by her mother. The trust provided that at the death of Elena, the trust was to terminate and assets were to be distributed to Elena’s two children. Elena, under the trust, had the right to demand $30,000 per year out of the corpus of the trust. If Elena failed to exercise the right to demand the money by December 31 of each year, the right lapsed.
1) What amount, if any, of the trust would be included in Elena’s Gross Estate if her mother created the trust on January 1 of this year and Elena died yesterday when the trust was valued at $500,000?
2) Same facts above, what is the result if the Mother created the trust on January 1, 2015 and Elena died yesterday? Assume the trust was valued at $300,000 on December 31 of each year and $300,000 when Elena died yesterday.
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