Jim inherits stock (a capital asset) from his brother, who died in March 2023, when the property had a \($20.7\) million FMV. This property is the only property included in his brother’s gross estate and there is a taxable estate. The FMV of the property as of the alternate valuation date was \($20.3\) million.

a. Why might the executor of the brother’s estate elect to use the alternate valuation date to value the property?

b. Why might Jim prefer the executor to use FMV at time of the death to value the property?

c. If the marginal estate tax rate is 40% and Jim’s marginal income tax rate is 24% and his rate on ANCG is 15%, which value should the executor use?