Dustin Owns All of the Stock of Gold Corporation Which

Dustin owns all of the stock of Gold Corporation which includes both common and preferred shares. The preferred stock is noncumulative, has no redemption date, and possesses no liquidation preference. In 1995, Dustin makes a gift to his adult children of all of the common stock. He dies in 2013 still owning the preferred stock. The value of the Gold stock on the relevant dates is: 1995 2013
Preferred $ 400,000 $ 500,000
Common 3,000,000 5,000,000
One of the tax consequences of this estate freeze is:

A) Dustin's gross estate includes $0 as to the stock.
B) Dustin's gross estate includes $5,000,000 as to the stock.
C) Dustin made a gift of $400,000 in 1995.
D) Dustin made a gift of $3,400,000 in 1995.
E) None of the above is correct.