Donald transferred stock in his closely held corporation to his daughter valued at $6 million. Donald and his wife, Alexis, elected to split the gift pursuant to § 2513. The transfer generated a gift tax liability of $700,000 for Donald and $300,000 for Alexis, but Donald paid the entire $1 million gift tax liability out of his funds. Donald died two years after the gift.
Are there any gift tax consequences to Donald from paying the portion of the gift tax liability owed by Alexis?
What are the estate tax consequences to Donald?