In February of the current year, Tom dies. Two years and nin…

In February of the current year, Tom dies. Two years and nine months before the date of death, Tom made a gift of stock valued at $2 million. Gift taxes paid on the transfer by Tom were $435,000 after applying $345,800 of unified credit ($780,800 – $345,800). At the time of his death, the gifted stock was valued at $2.3 million. The amount included in Tom’s gross estate from this transfer is