Kate lives in a house close to a local university, and she traditionally has rented a garage apartment in the back of her property to students for $750 per month. Kate wants to transfer the title to the property to her daughter and son-in-law, but she also would like to move into the garage apartment so that she can remain close to her family. Assume that Kate does so without paying her daughter and son-in-law any rent. What will be the estate tax consequences upon Kate's death? Is there a way the arrangement can be structured so as to avoid the application of 2036(a)(1) altogether?