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Taxpayer had an insurance policy on his life on which he had paid premiums for 8 years. The proceeds of the policy are $ 100,000

Taxpayer had an insurance policy on his life on which he had paid premiums for 8 years. The proceeds of the policy are $ 100,000 are to be paid to Sister on Taxpayer's death. In the 8th year, Taxpayer conveyed the policy to Sister; he did not retain any "incidents of ownership." Ignoring section 2035 (b) (inclusion of gift tax on gifts made during the 3 years before decedent's death), what is included in Taxpayer's gross estate if Taxpayer dies two years after the conveyance, but Sister has paid the post-transfer premiums?

A. $ 0

B. $ 20,000

C. $ 80,000

D. $ 100,000

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