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The adjusted gross estate of Keith, decedent, is $24 million. Included in the gross estate is stock in Gold Corporation (E & P of $2.6 million) , a closely held corporation, valued at $9.2 million as of the date of Keith's death. Keith had acquired the stock 12 years ago at a cost of $1.8 million. Death taxes and funeral and administration expenses for Keith's estate are $4.6 million. Gold Corporation redeems one-half of the stock from Keith's estate in a § 303 redemption to pay death taxes using property with a fair market value of $4.6 million (adjusted basis of $3.8 million) . Which of the following is a correct statement regarding the tax consequences of this redemption?
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