Estate of Doris F. Kahn, Deceased, LaSalle Bank, N.A., Trustee and Executor - Page 33

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          difference between transferring closely held corporate stock and            
          stocks in an IRA account that the estate consistently ignores,              
          but it also provides further confirmation of why we should not              
          intervene where Congress has already provided the necessary means           
          to reach a reasonable result.                                               
               The estate argues that it is illogical to value the IRAs as            
          though they were equivalent to the value of the underlying                  
          assets.  To illustrate this point, the estate compares three                
          assets with identical underlying assets:  A traditional IRA, a              
          securities account, and a Roth IRA.  The estate argues that these           
          three values should not have equal fair market value for Federal            
          estate tax purposes because valuing these assets at the same                
          amount would subject them to the same estate tax when the IRA               
          results in income tax to a beneficiary, and the securities                  
          account and Roth IRA would not subject a decedent’s beneficiary             
          to tax.13                                                                   
               We believe that our analysis of the willing buyer-willing              
          seller test and explanation of the purpose of section 691(c)                
          diminishes the importance of the difference between the tax                 
          consequences relating to these assets.  Hypothetical buyers and             
          sellers would agree on the same price for each of these items--             
          the amount of the account balances.  We have already illustrated            
          that a hypothetical buyer would not take into account the tax               


               13See secs. 1014, 408A.                                                




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