"I thought you said she would be paying taxes on the gift she paid her friend"

I explained how some of the giving might be characterized so that it falls under the annual limit. As for the Estate or Lifetime limit, there are no details to be able to tell you that, but you would need the person to be prepared, if that is an issue. In other words, did the person get any guidance on this, or have they already put themselves in a pickle? Because you would want to inform the person, if they are impacted.