During D$\text{'}$s life, D loaned Z$,$ an unrelated party, $$4\mathrm{.}75$ million. The note provided that Z was obligated to repay D the $$4\mathrm{.}75$ million ten years later, but if D died before Z repaid note, the note would be cancelled and Z would not be obligated to repay the $$4\mathrm{.}75$ 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? $($Ignore the impact of any accrued interest.$)$

Group of answer choices

The full $$4\mathrm{.}75$ million value of the SCIN is includible in D$\text{'}$s gross estate under section $691$ because it is income in respect of the decedent.

D$\text{'}$s estate is liable for gift tax on this deemed "gift" of $$4\mathrm{.}75$ million that D made to Z$.$

None of the $$4\mathrm{.}75$ million value of the SCIN is includible in D$\text{'}$s gross estate under section $2033.$

The full $$4\mathrm{.}75$ million value of the SCIN is includible in D$\text{'}$s gross estate under section $2033.$