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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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