Twenty college fraternity brothers each placed $2,500 in a mutual fund account. They agreed that upon the death of a fraternity brother, his beneficiary would receive $20,000 that was to be paid from the mutual fund account. The beneficiary of the last remaining fraternity brother would receive the balance remaining in the account. The mutual fund did very well. Earl was the last to die, at age 92, and his beneficiary received $250,000.
Is the $250,000 excluded from gross income? and do The proceeds not qualify as a gift, since the fraternity brothers paid $2,500 each per year to receive a future benefit (payment at death)?