Among the assets in a decedent's gross estate is stock in a closely held corporation that was left to a nephew. The interest passing to the nephew is required to bear the burden of all estate taxes and expenses. The relevant facts concerning this estate are:
Adjusted gross estate $1,600,000
Fair market value of stock in the
closely held corporation 700,000
Funeral expenses 30,000
Executor's commission 50,000
Federal and state death tax 160,000
What amount of closely held corporate stock can be redeemed under IRC Section 303 so that the redemption will be treated as a sale or exchange rather than a dividend distribution?
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