For many years, Howdy and his son, Doody, owned and operated Buffalo Corporation. Howdy owned 1,000 shares of the corporation while the remaining 400 shares outstanding were owned by Doody. Howdy had a basis of $200,000 in the stock before he died. On June 1 of this year, Howdy died. Howdys gross estate of $15,000,000 was comprised of various assets, including stock in Buffalo. Deductions for funeral and administrative expenses were $100,000 and Federal and state death taxes were $2,000,000. Of the remainder, $1,000,000 was left as a charitable contribution to the United Way and the balance, including the stock, was transferred to Howdys sole heir, Doody. In order to pay off the death taxes and other expenses, Howdys estate sold some of the stock back to the corporation. In order for the estates exchange to qualify for sale treatment, the lowest value that can be placed on the estates 1,000 shares is