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Abby was employed by Smallco, Inc., which had negotiated an agreement with Abby to pay her five times her annual salary if she worked for

Abby was employed by Smallco, Inc., which had negotiated an agreement with Abby to pay her five times her annual salary if she worked for Smallco, Inc. for at least ten years and agreed not to compete with Smallco, Inc. for two years after leaving Smallco, Inc. The agreement applied if Abby left Smallco, Inc. voluntarily, if she was terminated, if she retired, if she died while employed by Smallco, Inc., or if she became disabled. If Abby died before receiving payment, the payment would be made to her estate. Abby died after working 15 years for Smallco, Inc. and the company paid her estate $750,000 pursuant to the agreement. What are the estate tax consequences, if any?

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