18. Billy is a 50% shareholder and employee of ABC corporation. Billy's wife Bernadette owns 25% of ABC corporation and Billy's brother, Benny owns the other 25%. ABC corporation pays a dividend to all of its shareholders if the company has a net profit at calendar year end and the Board of Directors votes to make the payment. Billy dies on December 1, 2018. ABC corporation has a net profit and the Board votes for the dividend distribution on December 31, 2018. The dividend distribution would not be included in Billy's gross estate. True or False?