John, who is unmarried, died on March 3, 2020. His gross estate of $16.5 million includes First Corporation stock (400 of the 1,000 outstanding shares) worth $10 million or $25,000 per share ($10,000,000/400). This FMV amount also is the estate’s basis in the stock (see Chapter C:13). John’s brother, Myron, owns the remaining 600 shares. Deductible funeral and administrative expenses total $500,000. John, Jr. is the sole beneficiary of John’s estate. Estate taxes amount to $1.78 million.

a. Does a redemption of First Corporation stock from John’s estate, John, Jr., or John’s brother qualify for sale treatment under Sec. 303?

b. On September 10, 2020, First Corporation redeems 200 shares of its stock from John’s estate for $6 million or $30,000 per share ($6,000,000/200). How does the estate treat this redemption for tax purposes?