Answer:
$1,140,000
Step-by-step explanation:
A grantor retained annuity trust (GRAT) is used to lower taxes on financial gifts. After a certain time (it is not specified in the question) Paula's sons will receive the money left in the GRAT tax free.
To calculate Paula's taxable gift we have the total GRAT value minus the value of the annuity she retained for herself:
$2,000,000 - $860,000 = $1,140,000