Keith, 65, owns several rental tracts with a total fair market value of $100,000. He wants his son, Chris, to own the tracts as Chris's share of his estate. Keith is considering an annuity agreement whereby the tracts would be sold to Chris in return for Chris's promise to pay Keith an income for his life based upon Keith's original life expectancy. Upon Keith's death, Chris would own the rental tracts outright. What is one estate tax implication of this proposed private annuity for Keith's estate?

A) The value of Keith's gross estate increases because the present value of past annuity payments is included.

B) There is no estate tax liability because taxes are paid on the annuity during Keith's lifetime.

C) There is no estate tax liability because the annuity payments expire upon Keith's death.

D) The value of Keith's gross estate increases because the gross-up rule applies.