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Tom purchases life insurance naming himself as the insured and his wife Deanna as the beneficiary. If Tom dies during the term of the policy,

Tom purchases life insurance naming himself as the insured and his wife Deanna as the beneficiary. If Tom dies during the term of the policy, the life insurance company will pay out $1,000,000. In 2017, after making premium payments of $5,000, Tom transfers the policy to his wife Deanna. After the transfer, Deanna pays the next $5,000 of premiums before Tom's death in 2019. How much of the life insurance proceeds, if any, will be included in Tom's gross estate?

A. $0

B. $1,000,000

C. $1,000,000 but only if Tom has incidence of ownership over the policy

D. $5,000

E. $500,000

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