hello, please see attached assignment I need help with thanks

A deceased client's son walks into your office. His father's 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 client's 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 father's estate? For example, what specific incidents of ownership would the son need to have in his father's policy? Cite appropriate statutory authority, case law, and/or AICPA Code of Conduct or ABA Model Rules of Professional Conduct to support your conclusions. Please not I need an original paper not another student work 1-2 pages APA format Court Case: Rockwell v. Commissioner, 779 F.2d 931 (3d Cir. 1985) The court in Rockwell noted that the purpose of the incidents of ownership test in IRC 2042(2) was to prevent a decedent from continuing to enjoy the benefits of property until the time of death while escaping estate tax by formally transferring ownership at some earlier date. This resource supports the short paper. Court Case: Morton v. United States, 457 F.2d 750 (4th Cir. 1972) The Morton case is a good overview and discussion of the incidents of ownership of a life insurance policy. This resource supports the short paper. IRS Revenue Ruling: Rev. Rul. 84-179 IRC 2042(2) states, among other criteria, that a decedent will not be deemed to have incidents of ownership over an insurance policy on the decedent's life where the powers of the decedent over the policy are fiduciary powers that are not exercisable for the decedent's benefit. This resource supports the short paper. Court Case: Estate of Lumpkin v. Commissioner, 474 F.2d 1092 (5th Cir. 1973) Regarding gifts of life insurance, read IRC 2035(a), 2503(b), and 2512, and T.R. 25-2512-6 and T.R. 25.2503-3. IRC 2042(1) includes in the decedent's gross estate all proceeds of a life insurance policy that are receivable by the executor. IRC 2042(2) includes in the decedent's gross estate the amount received by a beneficiary other than the decedent's estate only if the decedent possessed an incident of ownership in the life insurance policy at the moment of her death. T.R. 20.2042-1 contains a broad definition of the incidents of ownership. The intent here is to prevent individuals from enjoying the benefit of their property during life while escaping gift tax on the property at death. The Lumpkin case addresses the question of whether an employee under the provisions of a group term life policy has incidents of ownership where the employee is given nothing more than the right to alter the timing and manner of enjoyment of the proceeds. This resource supports the short paper