Alternate Valuation Proposed Regulations (Reg. - 112196-07, Nov. 17, 2011)

(IRS reissued proposed regulation that provides guidance on the election and application of alternate valuation approach authorized by I.R.C. Sec. 2032 to estates; key points of the proposed regulations: (1) identification of transactions that involve sales, exchanges, distributions or dispositions of estate property; (2) such transactions occurring during six-month post-death period to be valued on transaction date unless transaction involves exchange of interest in entity includible in gross estate, or involves distribution from account or entity that decedent had interest in at death; (3) when  valuing such post-death transactions, decedent's percentage ownership/control in entity and degree of estate participation in post-death events irrelevant; (4) if post-death event deemed to have occurred at time of death, no distribution, etc., deemed to have occurred). 

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