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For Many Years, Howdy and His Son, Doody, Owned and Operated

question 53

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For many years, Howdy and his son, Doody, owned and operated Buffalo Corporation.Howdy owned 1,000 shares of the corporation while the remaining 400 shares outstanding were owned by Doody.Howdy had a basis in the stock before he died of $20,000.On June 1 of this year, Howdy died.Howdy's gross estate of $1,500,000 was comprised of various assets, including stock in Buffalo.Deductions for funeral and administrative expenses were $10,000 and Federal and state death taxes were $200,000.Of the remainder, $100,000 was left as a charitable contribution to the United Way and the balance, including the stock, was transferred to Howdy's sole heir, Doody.In order to pay off the death taxes and other expenses, Howdy's estate sold some of the stock back to the corporation.The maximum amount of stock that the estate may exchange that would qualify for sale treatment is

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