Carl is the sole shareholder of Production Corporation. The corporation owns a policy of life insurance on Carl's life, the proceeds of which are payable to the corporation, the beneficiary under the policy. What are the estate tax consequences of the policy when Carl dies?

A. The proceeds will be included in Carl's gross estate, because the corporation's incidents of ownership will be attributed to Carl through his stock holdings.

B. The proceeds will be included in Car's gross estate, because he is a controlling shareholder of Production Corporation

C. The proceeds will not be included in Carl's gross estate

D. Both A. and B. are correct