Corey Owns All of the Stock of Blond Corporation Which

Corey owns all of the stock of Blond Corporation which includes both common and preferred shares.The preferred stock is noncumulative,has no redemption date,and possesses no liquidation preference.In 1995,Corey makes a gift to his adult children of all of the common stock.He dies in 2008 still owning the preferred stock.The value of the Blond stock on the relevant dates is:

One of the tax consequences of this estate freeze is:

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