The adjusted gross estate of Debra, decedent, is $8 million. Debras estate will incur death taxes and funeral and administration expenses of $1 million. Debras gross estate includes stock in Silver Corporation that she had purchased twelve years ago for $600,000 (date of death fair market value of $3 million). At the time of her death, Debra owned 80% of the stock in Silver Corporation. Silver Corporation (E & P of $4 million) redeems all of the estates stock in the corporation for $3 million. Debras will names her daughter, Dena, who owns the remaining 20% interest in Silver Corporation, as her sole heir. With respect to this redemption, Debras estate has the following income

Please break this down, I don't understand why the remaining 2 million after expenses does not qualify for Sale/Exchange.