Estate of Cristofani v. Commissioner

D created an irrevocable inter vivos trust to which she contributed property during each of the two years preceding her death. The value of each contribution was $ 70,000. The primary beneficiaries of the trust were D's two children. D's five minor grandchildren had contingent remainder interests in the trust. In addition, the trust provided that D's two children and five grandchildren each had the unrestricted right to withdraw an amount not to exceed the amount of annual gift tax exclusion under sec. 2503(b)1Unless otherwise indicated, all section references are to the Internal Revenue Code…