Frederic Kohler died on March 4, 1998, owning 12.85 percent of the stock in Kohler Co., a closely held company. On May 11, 1998, before the alternate valuation date (AVD), which is six months after the date of death, the stock was exchanged for stock subject to certain transfer restrictions as part of a tax-free reorganization under Internal Revenue Code Section 368(a). The estate subsequently elected to use the AVD to value the stock, reporting the stock value on the estate tax return based
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