In 2005, Joe who is 75 years old, created a 10 year GRAT into which he transferred $1 million of securities. Joe’s basis in the securities is $250,000. At the time Joe transferred the assets into the GRAT, the IRC Sec. 7520 rate was 4.8%. Joe’s annuity interest was valued at $311,000. At the end of the 10 years, the assets within the trust transfer to Joe’s brothers and sisters. Joe dies in 20012 when the value of the trust is $1,200,000.

What amount of the trust assets will be included in Joe’s gross estate?

Select one: a. Zero b. $ 311,000 c. $ 1,000,000 d. $ 1,200,000