Jim inherits stock $($a capital asset$)$ from his

brother, who died in March $2023,$ when the property had a $$20\mathrm{.}7$ million FMV$.$ This property is

the only property included in his brother$$s gross

estate and there is a taxable estate. The FMV of

the property as of the alternate valuation date

was $$20\mathrm{.}3$ million.

a$.$ Why might the executor of the brother$$s estate elect to use the alternate valuation date to

value the property?

b$.$ Why might Jim prefer the executor to use FMV

at time of the death to value the property?

c$.$ If the marginal estate tax rate is $40\%$ and Jim$$s

marginal income tax rate is $24\%$ and his rate

on ANCG is $15\%,$ which value should the executor use?