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included in the gross estate as of an alternate valuation date,
which is the earlier of the date on which the property is
disposed of or the date 6 months after the decedent's death. See
sec. 2032(a)(1) and (2).8 The election to determine the value of
the property on the alternate date must be made on the estate tax
return, and the election may not be made if the return is filed
more than 1 year after the time prescribed by law (including
extensions) for filing the return. See sec. 2032(d)(1) and (2).9
The return in this case was due no later than July 13, 1994,
8SEC. 2032. ALTERNATE VALUATION.
(a) General.--The value of the gross estate may be
determined, if the executor so elects, by valuing all
the property included in the gross estate as follows:
(1) In the case of property distributed, sold,
exchanged, or otherwise disposed of, within 6 months
after the decedent's death such property shall be
valued as of the date of distribution, sale, exchange,
or other disposition.
(2) In the case of property not distributed,
sold, exchanged, or otherwise disposed of, within
6 months after the decedent's death such property
shall be valued as of the date 6 months after the
decedent's death.
9Sec. 2032(d) provides:
(1) In general.--The election provided for in this
section shall be made by the executor on the return of
the tax imposed by this chapter. Such election, once
made, shall be irrevocable.
(2) Exception.--No election may be made under this
section if such return is filed more than 1 year after
the time prescribed by law (including extensions) for
filing such return.
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