Problem
Taxpayer had an insurance policy on his life on which he had paid premiums for 8 years. The proceeds of the policy are $100,000 and are to be paid to Sister on Taxpayer's death. In the 8th year, Taxpayer conveyed the policy to Sister; he did not retain any "incidents of ownership." Ignoring section 2035(b) (inclusion of gift tax on gifts made during the 3 years before decedent's death), what is included in Taxpayer's gross estate if Taxpayer dies two years after the conveyance, but Sister has paid the post-transfer premiums?