Ruth Ames died on January 10, 2021. In filing the estate tax return, her executor, Melvin Sims, elects the primary valuation date and amount (fair market value on the date of death). On March 12, 2021, Melvin invests $30,000 of cash that Ruth had in her money market account in acquiring 1,000 shares of Orange, Inc. ($30 per share). On January 10, 2021, Orange was selling for $29 per share. The stock is distributed to a beneficiary, Annette Rust, on June 1, 2021, when it is selling for $33 per share.

Melvin wants you to determine the amount at which the Orange shares should appear on the Federal estate tax return and the amount of Annette’s adjusted basis for the stock. Write a letter to Melvin in which you respond to his inquiry, and prepare a memo for the tax files. His address is 100 Center Lane, Miami, FL 33124.