At the time of her death on September 4, 2016, Alicia held the following assets:

Fair Market ValueBonds of Emerald Tool Corporation$900,000Stock in Drab Corporation1,100,000Insurance policy (face amount of $400,000) on the life of her father, Mitch80,000*Roth IRAs$300,000*Cash surrender value.

Alicia was also the life tenant of a trust (fair market value of $2,000,000) created by her late husband Bert. (The executor of Bert’s estate did not make a QTIP election.) In October, Alicia’s estate received an interest payment of $11,500 ($6,000 accrued before September 4, 2016) paid by Emerald and a cash dividend of $9,000 from Drab. The Drab dividend was declared on August 19 and was payable to date of record shareholders on September 5, 2016. Although Mitch initially survives Alicia, she is the designated beneficiary of the policy. The IRAs are distributed to Alicia’s children.

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Mitch is killed by a rock slide while mountain climbing in November 2016, and the insurer pays Alicia’s estate $400,000.

On November 7, 2016, Alicia’s estate receives from the IRS an $8,000 income tax refund on the taxes she paid for the preceding calendar year.

The amount included in Alicia’s gross estate is $