In year 1, D entered into a contract with an insurance company under which D paid the company $750,000 then and there; they agreed that beginning in year 10, the company would pay D $9,000 per month for life and, after D's death, the company would make like payments to D's spouse S for as long as S should live. However, D died in year 8, survived by S.

What is S's income tax basis in the right to receive the future payment in part (d)? If D intended to make charitable donations at death, should D consider leaving other property to S and the pension proceeds to charity?