At the time of her death in 2015, Wanda has an adjusted gross estate of $6.5 million. Her estate includes the family farm, with a most suitable use value of $3.3 million and a current use value of $2.3 million. The farm is inherited by Jim, Wanda’s son, who has worked it for her since 1995. Jim plans to continue farming indefinitely.

a. Based on the informationgiven,is the§ 2032A election availabletoWanda’sestate?

b. If so, what value must be used for the farm?

c. Suppose Wanda had made a gift of securities (fair market value of $500,000) to her cousin six months before her death. Does this fact affect your analysis? Explain.