At the time of his death, Clint recorded an adjusted gross estate of $6.2 million. Included in the estate is a 15% capital interest in a partnership. Clint's interest is valued $2.6 million. Except for Clint's daughter Phoebe, none of the other 48 partners are related to him. Phoebe holds a 10% capital interest. Does Clint's estate qualify for the Section 6166 election? Explain.