Burt and Eve are husband and wife and have always lived in New York, a common law state. In 1990 and using separate funds, they bought an annuity from an insurance company-the purchase price was furnished 1/3 by Burt and 2/3 by Eve. Under the terms of the contract, Burt is to receive $50,000 per month for life when he reaches age 65. If Eve survives Burt, she is to receive $30,000 per month for her life. Burt dies first in 2011, at which time the value of Eve's survivorship annuity is $2,400,000. As to this annuity, how much (if any) is included in Burt's gross estate?
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