Zan Zwang, a widower, died September 4, 2014, and was survived by his three adult children. On September 4, 2011, he gave each child stock valued at $2 million and paid gift tax with the return he filed in 2012. Exclusive of any gross-up, Zwang's gross estate is valued at $6.2 million. You are preparing Zwang's estate tax return, and your manager advises you that she seems to recollect reading a technical advice memo addressing when the three-year period begins in this context. Prepare a memo to your manager in which you address when the three-year period begins and, thus, whether Zwang's gross estate must include a gross-up for the taxes on the 2011 gift?