The decedent's will states in part "I give, devise and bequeath the sum of $20,000 to Joe". The decedent's personal representative writes Joe a check from the estate for $20,000 and in that tax year the estate has $40,000 DNI. Joe will be income taxable on

A-$20,000.

B-$-0-.

C-$20,000 if a first tier beneficiary , zero if a second tier beneficiary.

D-$-0- if the personal representative makes the section 645 election.