Essay
Guy died this year. His estate includes a closely held business interest valued at $400,000 and other property valued at $675,000. Guy's allowable Sec. 2053 and 2054 deductions total $75,000. Within three years of death, partly in hopes of qualifying his estate for the installment payment allowed under Sec. 6166 treatment, Guy made gifts of listed securities of $350,000 (at 2002 valuations)and paid no gift tax on the gift. Is Guy's estate eligible for Sec. 6166 treatment?
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No, it fails the 35% test in o...View Answer
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