Janet Mason timely filed a 2017 gift tax return to report the gift on June 3, 2017, of closely held stock in Mason Meat Co., Inc. The tax return, which your firm prepared, reflected a value of $1,500 per share (determined by an appraiser) and a taxable gift of $6.3 million. This was Janet's first taxable gift, and she exhausted her unified credit then available of $2,141,800. On October 22, 2018, Janet's father, Mason Meat's CEO and founder, died unexpectedly at age 59. Two months prior to her father's death the firm had recalled much of its meat from distributors and supermarkets because of contamination in the meat plant. The plant closed for six weeks while the problem was corrected. An appraiser valued the stock for her father's estate at $1,000 per share. Janet, a new client, would like for your firm to prepare an amended gift tax return and value her gift at $1,000 per share because of the decline in value resulting from the two events described. She would like a refund of the gift tax she paid and have some of her unified credit re-stored. Prepare a memo that addresses whether Janet should be entitled to a refund of the gift tax paid and restoration of some of her unified credit.