Roberts$$s gross estate includes $1,500$ shares of stock of Queen Consolidated Inc. $($basis to Robert of

$$1\mathrm{.}2$ million, fair market value on date of death of $$8\mathrm{.}2$ million$).$ The estate will incur $$4\mathrm{.}4$ million of

death taxes and funeral and administration expenses, and the adjusted gross estate is $$18$ million.

Oliver, Robert$$s son and sole heir of his estate, owns the remaining $500$ shares of Queen$$s

outstanding stock. In the current year, Queen $($E&P of $$10$ million$)$ redeems all of the estate$$s $1,500$

shares for $$8\mathrm{.}2$ million. What are the tax consequences of the redemption to Robert$$s estate?