Reference no: EM131795260
Donna contributes $1,000,000 of appreciated stock to a trust and appoints a commercial bank trustee. Is all or any portion of the trust includible in Donna's estate under IRC §2036(a)(1) if, in the alternative, the terms of the trust are as follows:
a. One-half of the trust income is to be paid annually to Donna for life, one-half to be accumulated. At Donna's death, the corpus is to be distributed to her son, Charlie, or Charlie's estate.
b. Same as a. except that Donna is not entitled to any trust income for the year prior to her death.
c. Same as a. except that the term of the trust is only for 10 years. Upon termination, the corpus is to be distributed to Charlie or Charlie's estate. Donna dies 6 years after the formation of the trust.
d. The trustee, in her sole discretion, may distribute as much of the net trust income to or for the benefit of Charlie as the trustee determines to be necessary or appropriate for the support or maintenance of Charlie. Any net income not so distributed shall be accumulated and added to principal. Donna dies when Charlie is 15 years old. Suppose Charlie were 25?
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