Willie purchased a whole-life insurance policy on his brother, Benny. Under the policy, the insurance company will pay the named beneficiary $100,000 upon the death of the insured, Benny. Willie names Tess the beneficiary, and upon Bennys death, Tess receives the proceeds of the policy, $100,000. Identify the transfer tax implications of this arrangement. Required: At the time of purchase of the policy. Upon Bennys death.