Grace treated an irrevocable trust to pay the income to Sam(her spouse) for life, and at his death to distribute the trust property to their children, Ellen and Frank. Ellen and Frank are Co-Trustees. Sam, Ellen and Frank agree that Ellen and Frank will each be paid $50,000 a year to serve as Trustee and that this amount will be paid from the trust's income. What are the gift tax consequences, if any, of this arrangement? Detailed answer with references, please