3. X took out a 20M life insurance policy with AAA Life Insurance Co. He designated his only child as the sole beneficiary of the proceeds. Upon X's death, his administrator is contemplating of excluding proceeds from the computation of his gross estate to minimize the estate tax liability of the decedent. The BIR, on the other hand, is insisting that the 20M should be included as part of the gross estate and the estate tax be imposed thereon. What is the proper tax treatment of the insurance proceeds