Sharon transfers to Russ a life insurance policy with a cash surrender value of $27,000 and a face value of $100,000 in exchange for real estate. Russ continues to pay the premiums on the policy until Sharon dies 7 years later. At that time, Russ has paid $12,000 in premiums, and he collects the $100,000 face value. How much of the proceeds, if any, is taxable to Russ?