Question
George died last year and his gross estate is $6,000,000. Georges estate expects to incur a total of $300,000 of death taxes and allowable deductions
George died last year and his gross estate is $6,000,000. Georges estate expects to incur a total of $300,000 of death taxes and allowable deductions for expenses and losses under 2053 and 2054. Georges gross estate includes stock in X Corporation (fair market value$600,000) and Y Corporation (fair market value$1,200,000). The fair market value of all of the outstanding X and Y stock is $4,200,000 and $4,800,000, respectively. Georges wife, Adele, also owns $600,000 of X stock. (She and George held a total of $1,200,000 of X stock as tenants-in-common during his life.)
Question: If Y Corporation redeems shares from Georges estate, will the redemption qualify for exchange treatment under 303?
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