Question
D's gross estate consists of the following assets, with different values as of the indicated dates: Asset Date of Death Six Months After Date of
D's gross estate consists of the following assets, with different values as of the indicated dates:
Asset | Date of Death | Six Months After Date of Death |
Real Estate | $5,300,000 | $5,200,000 |
Stocks | $550,000 | $600,000 |
Inventory | $500,000 | $510,000 |
Patent with 5 years to run at death | $150,000 | $135,000 |
Receivables | $100,000 | $80,000 |
Total | $5,600,000 | $5,525,000 |
The stocks were distributed to D's sole beneficiary three months after D's death when they were worth $560,000. Dividends of $2,000 on the stock were received by the estate after D's death, but before the stock was distributed. Royalties on the patent of $20,000 were received by the estate in the first six months after D's death. In addition, $20,000 of receivables had been collected in the first six months.
a. Can the personal representative-elect to value the estate under § 2032?
b. What would be the impact under § 2032 if (1) D died before the record date for the dividend, and (2) the estate collected an additional $20,000 of receivables during the first six months after D's death?
c. How would the results differ if D died after the record date for the dividend?
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a Can the personal representativeelect to value the estate under 2032 Section 2032 of the Internal Revenue Code allows the executor or personal repres...Get Instant Access to Expert-Tailored Solutions
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