At the time of his death in 2015, Clint had an adjusted gross estate of $6.2 million. Included in the estate is a 15% capital interest in a partnership. Clint’s interest is valued at $2.6 million. Except for Clint’s daughter Phoebe, none of the other 48 partners are related to him. Phoebe holds a 10% capital interest.

a. Does Clint’s estate qualify for the § 6166 election?

b. Suppose that one year prior to his death, Clint gave $1.5 million in cash and securities to Phoebe. Does this change your analysis? Explain.