Of the following statements, which is false?

A) The availability of the unlimited marital deduction merely postpones the potential estate tax due.

B) Property that is not included in the decedents gross estate cannot qualify for the unlimited marital deduction.

C) The death benefit of a life insurance policy included in a decedents gross estate is not eligible for the unlimited marital deduction, even if the surviving spouse is the listed beneficiary and receives the proceeds.

D) An individual can use the unlimited marital deduction during life to fund the surviving spouses applicable estate tax credit. The best property to transfer in this method is the property that is expected to appreciate in value after the transfer to the surviving spouse.