On January 1, 2003, S transferred $500,000 of securities into a revocable trust for the sole benefit of her brother U.On January 1, 2012, S amends the trust instrument to make the trust irrevocable.S retains no control over the trust assets.On January 1, 2012, the trust assets have a fair market value of $430,000.Based on these facts,

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When S transferred the securities into a revocable trust, there was no gift for tax purposes because S retained control and the ability to revoke the trust. The gift occurs when the trust is amended to become irrevocable, removing S's control over the assets. At this point, the value of the gift is the fair market value of the trust assets on the date the trust became irrevocable, which was $430,000 on January 1, 2012.

On January 1, 2003, S Transferred $500,000 of Securities into a Revocable