Assume that Belinda passed away on June 1, 2023, and is survived by her husband, and two sons. Belinda's only lifetime taxable gift was made in October 2020 in the taxable amount of $13.25 million. She did not elect gift splitting, and she paid all required gift taxes in excess of the 2020 unified credit at that time. By the time of her death, the value of the gifted property (stock) had declined to $5.1 million.

Since she passed away within 3 years of making the gift is the gift included in her gross estate? If so how much of the gift and how much of the gift tax paid?