t the time of her death, June had an adjusted gross estate of $16,000,000. Included in the estate were the following business interests.   Fair Market Value A 30% capital interest in the JX Partnership $5,700,000 A 25% interest (i.e., 250 shares out of 1,000) in Silver   Corporation 500,000 A catering service operated as a sole proprietorship 950,000   JX has 32 partners, while Silver lists 30 shareholders. None of the other partners or shareholders are related to June. Can June’s estate qualify for an election under § 6166? Explain.

SWFT Corp Partner Estates Trusts
42nd Edition
ISBN:9780357161548
Author:Raabe
Publisher:Raabe
Chapter19: Family Tax Planning
Section: Chapter Questions
Problem 40P
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At the time of her death, June had an adjusted gross estate of $16,000,000. Included in the estate were the following business interests.

  Fair Market Value
A 30% capital interest in the JX Partnership $5,700,000
A 25% interest (i.e., 250 shares out of 1,000) in Silver  
Corporation 500,000
A catering service operated as a sole proprietorship 950,000

 

JX has 32 partners, while Silver lists 30 shareholders. None of the other partners or shareholders are related to June. Can June’s estate qualify for an election under § 6166? Explain.

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