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Generally, when a couple has set up a life estate the estate does not pass to the beneficiary until both individuals have passed away. The life estate is a legal document that has tax consequences so you may want to seek legal advice if you have any questions regarding the terms of the life estate.
If the "gift" doesn't occur until the death of all life tenants, it still seems strange that the gift tax is paid before their death.
That's not what @Leonard Smith said.
"Generally, when a couple has set up a life estate the estate does not pass to the beneficiary until both individuals have passed away."
A donor gives a gift while still alive. A decedent leaves an inheritance after death to a beneficiary.
A life estate refers to property owned by an individual during their lifetime and prevents beneficiaries from selling the property before death.
My bad on terminology -- was not trying to disagree with @LeonardS 's response.
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