At the time of her death on October 4, Nancy Was the sole life beneficiary of a trust (assets worth $ 2 million) created 10 years ago by George (Nancy's husband). The transfer was by gift of securities then worth $ 500,000 George and Nancy's children are the remainder beneficiaries.

Owned stock in Yahoo Corporation (basis of $ 800,000 and fair market value of $1 million). On September 7, a dividend of $48,000 was declared on the stock payable to all shareholders of record on October 3. The $48,000 was received by George's executor on October 19. Made a taxable gift of $400,000 in a prior tax year.

As to these transactions, George's gross estate includes: