During D$\text{'}$s life, D loaned B$,$ an unrelated party, $$2\mathrm{.}25$ million. The note provided that B was obligated to repay D the $$2\mathrm{.}25$ million ten years later, but if D died before B repaid note, the note would be cancelled and B would not be obligated to repay the $$2\mathrm{.}25$ million to D$\text{'}$s estate. The note was properly structured as a self cancelling installment note $($SCIN$)$ as discussed in class. Which of the following statements best describes the gross estate tax consequences of this SCIN arrangement?