Gerald and Pat are husband and wife and live in New York. In 2005, they purchase an insurance policy (joint ownership) on Gerald's life and designate their daughter, Marie, as the beneficiary. The policy has a maturity value of $4,000,000 and lists ownership as tenants in common. Gerald dies first in 2013 and the insurance proceeds are paid to Marie. As to the proceeds:
A) Gerald's gross estate includes $0, and no other tax consequences ensue.
B) Gerald's gross estate includes $4,000,000.
C) Gerald's gross estate includes $2,000,000, and Pat makes a gift to Marie of $2,000,000.
D) Gerald's gross estate includes $0, and Pat makes a gift of $4,000,000 to Marie.
E) None of the above
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