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Mrs. Okada, aged 82, gifted $1,000,000 of highly appreciated growth stock to her grandchildren and paid $400,000 in gift tax from her personal checking account in 2025. She died in 2026 when the stock was valued at $1,200,000.

Under the Section 2035 'three-year rule,' what amount, if any, is brought back into her gross estate regarding this transfer?

  1. $400,000
  2. $1,400,000
  3. $1,000,000
  4. $0

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