The adjusted gross estate of Debra, decedent, is $16,000,000. Debra's estate will incur death taxes and funeral and administration expenses of $2,000,000. Debra's gross estate includes stock in Silver Corporation that she had purchased 12 years ago for $1,200,000 (date of death fair market value of $6,000,000). At the time of her death, Debra owned 80% of the stock in Silver Corporation. Silver Corporation (E & P of $8,000,000) redeems all of the estate's stock in the corporation for $6,000,000 million. Debra's will names her daughter, Dena, who owns the remaining 20% interest in Silver Corporation, as her sole heir. With respect to this redemption, Debra's estate has the following income: