Ellen owns a $60\%$ interest in the stock of a corporation$/$the remaining $40\%$ is owned by her brother. Ellen transfers a $15\%$ interest to her son. $2$Y later, Ellen dies owning a $45\%$ interest in the corporation. Ellen's will devised a $36\%$ interest to her son, and the remaining $9\%$ interest is devised in equal shares to her nephews and nieces, $9$ total. Ellen's executor asserts a minimal value on the $1\%$ stock interest left to each niece and nephew. Comment on the estate's argument.