Roger holds a controlling interest in a corporation which he also serves as an employee of$.$ Roger enters into a split$-$dollar arrangement with the corporation. The corporation agrees to pay a portion of the premium attributable to the increase in the cash surrender value, and it is entitled to receive the cash value of the policy upon Roger's death. An irrevocable trust created by Roger owns the policy, and the trust is entitled to the policy proceeds in excess of the cash surrender value that must be paid to the corporation. In reviewing the split$-$dollar arrangement on behalf of Roger from an estate tax planning standpoint, what red flags should you look for?