Ellen owns a 60 percent interest in the stock of a corporation; the remaining 40 percent is owned by her brother. Ellen transfers a 15 percent interest to her son. Two years later, Ellen dies, owning a 45 percent interest in the corporation. Ellen's will devised a 36 percent interest to her son, and the remaining 9 percent interest is devised in equal shares to her nephews and nieces (9 total). In particular, what factors will be relevant to the stock's valuation? Comment on the government's argument. Comment on the estate's argument. If Ellen desired to retain the right to vote on the stock during her lifetime but wanted to make transfers of the economic rights to the stock, how could Ellen have accomplished her goals? [Note that the straightforward approach of transferring the stock while retaining the legal right to vote the stock is effectively precluded by 2036(b).]