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Vira was sole shareholder of Koltana, Inc., which held a $1,000,000 term insurance policy on Vira's life payable to her son Ivan. Two years ago,

Vira was sole shareholder of Koltana, Inc., which held a $1,000,000 term insurance policy on Vira's life payable to her son Ivan. Two years ago, when the stock of Koltana was worth $4,000,000, Vira gave the stock to Ivan and paid of gift tax of $1,545,800 on the transfer. At Vira's death last month, Koltana (exclusive of the insurance policy) was worth $5,000,000. Shortly after Vira's death, Beclair Insurance paid Ivan the $1,000,000 policy proceeds. What amount is includible in Vira's estate and why.

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