Phil contributed $300,000 to an irrevocable trust and did not retain any right to the trust’s assets. The income beneficiary of the irrevocable trust was Phil’s nephew, and the remainder beneficiary of the irrevocable trust was Phil’s niece. At the time of the transfer, Phil paid gift tax of $20,000. Phil died two years later, when the value of the irrevocable trust was $1,200,000. Based solely on there facts, how much is included in Phil’s gross estate?