Question - Taxpayer had an insurance policy on Taxpayer's life on which Taxpayer had paid premiums for ten years. The proceeds of the policy are $200,000 and are to be paid to Sibling on Taxpayer's death. In the tenth year, Taxpayer conveyed the policy to Sibling, but unless stated to the contrary, Taxpayer continued to pay the premiums. Taxpayer did not, however, retain any "incidents of ownership".
What are the estate tax consequences if Sibling took out the policy on Taxpayer's life two years prior to Taxpayer's death, but Taxpayer paid all of the premiums on the policy?