A married 72 year-old with two children had a real estate company valued at $75 million and was concerned about what would happen to the company at his death. He had recently learned that the estate tax would be $30 million and that the proceeds from his $10 million life insurance contract would be subject to an additional $4 million of taxes. Furthermore, the real estate market was booming and conservative growth models showed that the business could be worth in excess of $100 million in 10 years, creating another $10 million of estate taxes.