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Sengupta died on February 1, Year 1, and bequeathed two different assets to a beneficiary, Roberts. Asset One was distributed to Roberts on April 24,

Sengupta died on February 1, Year 1, and bequeathed two different assets to a beneficiary, Roberts. Asset One was distributed to Roberts on April 24, Year 1; Asset Two was distributed to Roberts on October 25, Year 1. The executor of Sengupta's estate makes a qualified alternate valuation date election. The basis of each bequeathed asset will thus be the fair market value on which date

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