hw0799

^Thanks for the reply, good luck tomorrow!
I just looked at this again, unless I am reading the question or the vignette wrong, the choice should be irrevocable.
Basically, you get a 20% slap for revocable for the ENTIRE amount of the portfolio.
In the irrevocable, you only get 20% deducted from the CAP GAINS. Assuming the 800k basis, you are better off in the irrevocable because the basis is not taxed at 20% unlike the revocable (estate taxes applies).