John and Mary Larsson purchased a joint and survivorship annuity from the Life and Death Insurance Co. John paid for the annuity and died 11 years later, at which time Mary’s survivorship interest had a value of $50,000. Mary was killed in a car crash four months later, having collected

$2,000 since her husband’s death.

a. Must the date ofd eath value be used, even though it is known that the asset is worthless prior to the due date of the return?

b. Does it make a difference that the alternate valuation date is elected? (See Estate ofJ ohn A. Hance, 18 TC 499, Dec. 19,025 (1952), Acq. 1953-1 CB 4, and Code Sec. 2039

(a) and (b).)