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Jean died in a common-law state in 2023 and was survived by her husband, Loren, and three adult children. Jean's gross estate, all of which was owned solely in her name, was composed of the following assets and date of death fair market values:

 

Assets Values
Common stock $ 4,900,000
Residence 750,000
Personal property 60,000
IRAs 3,450,000
Hummel figurines 175,000
Total Assets $ 9,335,000

 

Jean's only liabilities, together with their date of death balance, were as follows:

 

Liabilities Balance
Mortgage on residence $175,000
Car loan 8,000
Total $183,000

 

The following is a list of all of the gratuitous transfers that Jean made during her lifetime:

 

  • 2000: Placed the common stock listed above in an irrevocable trust in which she retained the right to a 5% distribution of the trust account revalued annually for 25 years with the remainder to her children at her death; the date of gift fair market value of the stock was $190,000; the value of Jean's retained interest on the date the gift became complete was $90,000
  • 2001: A cash gift to her niece of $30,000, which Loren agreed to split
  • 2005: Paid the University of Iowa $11,000 for her youngest child's tuition
  • 2020: Gave her brother $70,000 in cash, which Loren agreed to split

 

Jean's will, executed in 2000, gave the residence and personal property to Loren and the Hummel figurines to a qualified charity. Jean's three children were designated as equal beneficiaries of her IRAs. Each beneficiary of Jean's estate was to pay any transfer tax due on the portions of the estate received. Her will also stipulated that any real property was to be received subject to the mortgage. Further, her will stipulated that funeral and administrative expenses were to be paid equally by her husband and three children. These funeral and administrative expenses amounted to $60,000 for Jean's estate. Jean's estate paid state death taxes in the amount of $4,184, and will pay off the car loan.

Which one of these amounts most closely approximates the net federal estate tax due from Jean's estate? Use the Unified Federal Estate and Gift Tax Rates table.

 
 
A)
$1,455,800
 
 
B)
$999,699
 
 
C)
$0
 
 
D)
$106,517
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