Naomi died in 2020 with an adjusted gross estate of $5,600,000. Naomi's gross estate included 80% Of the stock of Wolf Creek corporation valued at $1,980,000. Naomi had purchased the stock in Wolf Creek corporation in 1996 for $120,000. The death taxes in funeral expenses and administrative expenses for Naomi's estate totaled $525,000. The executor of Naomi's estate redeemed $525,000 of the stock Naomi owned in Wolf Creek corporation immediately after the death of Naomi. As a result of this transaction, Naomi's estate has a taxable dividends income of space (assume that Naomi's estate does not qualify for any redemption under section 302 (b) and Wolf Creek corporation has Substantial earnings and profits (E and P).