Tax research memo

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“Daniel Long, age 75, is a widower with considerable wealth. his only family is his granddaughter, Marcia and her four children. Marcia’s parents, Daniel’s son and daughther in law, were killed in an automobile accident. using securities worth $3 million, Daniel would like to create a trust, life estate to Marcia, remainder to her children. he is hesitant to do so because of the tax generationskipping transfers. write a letter to daniel advising him on this matter and any gift tax that the transfer would generate. (Daniel has exhausted his unified transfer credit)” Please write a tax research memo answering the problem citing the appropriate sources within the tax code.

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