Jacob owns a modest house on a large, ocean-front lot in a region where development is booming. Seeking to cap his estate-tax exposure, Jacob sells a remainder interest in the property to Alice Jacob's committed partner to whom he is not married for its actuarial value. Jacob continues to reside in the property pursuant to his retained life estate for the remainder of his lifetime. At the time of the sale of the remainder, the fee interest was valued at $3 million, and the remainder was valued at $1 million. Upon Jacob's death five years later, the value of the property had increased to $5 million. Discuss the estate tax consequences to Jacob's estate