Estate of Frederick Carl Gloeckner, Deceased, Joseph A. Simone, and Douglas Dillon, Co-Executors - Page 16

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          disregard the 1987 redemption agreement because of the 1991                 
          amendment.  The 1987 redemption agreement was entered into before           
          the effective date of section 2703.  The 1991 amendment, however,           
          was entered into on April 28, 1991, which, with regard to                   
          amendments, is after the effective date of section 2703.                    
          Nevertheless, April 28, 1991, also is a date after January 28,              
          1991 (the alternate valuation date).  As of that date                       
          (January 28, 1991) the 1987 redemption agreement was unamended.             
          Section 2703 is inapplicable.                                               
          IV.  1987 Redemption Agreement Not Controlling                              
               A.  Background                                                         
               Section 2001(a) imposes a tax on “the transfer of the                  
          taxable estate of every decedent who is a citizen or resident of            
          the United States.”  Section 2031(a) states:  “The value of the             
          gross estate of the decedent shall be determined by including to            
          the extent provided for in this part, the value at the time of              
          his death of all property, real or personal, tangible or                    
          intangible, wherever situated.”  Section 2032 provides that the             
          value of the gross estate may be determined as of a date that,              
          generally, is 6 months after the decedent’s death, if the                   
          executor so elects.                                                         
               The standard for valuation is fair market value.  Section              
          20.2031-1(b), Estate Tax Regs., defines fair market value as “the           
          price at which the property would change hands between a willing            
          buyer and a willing seller, neither being under any compulsion to           




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