A deceased clients son walks into your office. His fathers life was insured for $10 million and he had $10 million in other assets in his estate at the time of death. Assuming the client had used none of his unified credit, had no deductions, and left his entire estate to his son, what should the clients estate tax liability be? The client had purchased the policy many years ago and has been paying the premiums himself.

What facts would have to change in order for the $10 million insurance proceeds to not be included in the fathers estate? For example, what specific incidents of ownership would the son need to have in his fathers policy?