Jan funded an irrevocable trust with $3 million of dividend paying stock. She gave her husband Jeremy a life estate in the trust. The trust directs that upon Jeremy's death the remainder will be paid to Jan, if she is living or to her daughter Esther if she is not. Jan retained a reversionary interest in the trust greater than 5% at her death. Which of the following statements is NOT correct?
a. Esther has a contingent interest because she cannot receive the remainder interest until she survives Jan
b. The value of the remainder interest is included in Jan's gross estate
c. The total FMV of the trust is included in Jan's gross estate
d. If Jan had retained a reversionary interest of 4%, then the value of the trust would not be included in her gross estate