Angie and her daughter, Ann, who are the only shareholders of Bluebird Corporation, each paid $100,000 four years ago for their shares in Blue bird. Angie also owns 20% of the stock in Redbird Corporation. The Redbird stock is worth $500,000, and Angie's basis in the stock is $50,000. Angie dies in the current year leaving all of her property to her husband, Gary, but Ann wants to be the sole shareholder of Bluebird Corporation. Bluebird has assets worth $4 million (basis of $700,000) and E & P of $1 million. Angie's estate is worth approximately $6 million.

Angie has made gifts during her lifetime to Ann. What are the tax issues for Angie's estate, Ann, and Bluebird?