Molly Caruso was the sole shareholder of Seneca Resorts Inc. Her basis in the stock was \(\$ 200,000\). Molly died when her stock was worth \(\$ 5,000,000\). Her gross estate, including the stock, was \(\$ 7,500,000\), funeral and administrative expenses amounted to \(\$ 180,000\) and estate taxes totaled \(\$ 720,000\). Seneca Resorts redeemed 20 percent of the stock from the estate for \(\$ 1,200,000\) when its \(E \& P\) was \(\$ 600,000\). What are the tax consequences to Molly's estate and Seneca Resorts?