Gail creates a trust and names herself as the sole trustee. John is Gail's son and Dana is Gail's daughter. According to the trust, the income interest is for John's life and, upon John's death, the trust terminates and the corpus is distributed to Zoe (unrelated) or Zoe's estate. The trustee has the sole discretion whether to distribute income or principal to either John or Dana. Gail predeceases John, Dana, and Zoe.

Assuming the value of the trust at the time of Gail's death is $2,000,000, how much value from the trust should be included in Gail's gross estate if any?

A. $2,000,000

B. $0

C. $2,000,000 less the remainder interest

D. $1,000,000

E. None of the Above