Prepare an estate tax return (Form 706) for Adam Zugg of 45 Cornfield Place, Midwest City, IL 60000. Adam died October 31, 2019. He was survived by his wife, Callie, and their son, Zebulon. At the time of his death, Adam was employed by a farm equipment distributor as its office manager. The executor reports that he has discovered the property listed below.

Checking account, Adam and Callie, joint tenants with
right of survivorship . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 10,200
Stocks in public companies in the name of Adam . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10,300,000
Undeveloped land (not leased or farmed) in the name of Adam . . . . . . . . . . . . . . . .  4,400,000
Qualified retirement plan funded by Adam’s employer . . . . . . . . . . . . . . . . . . . . . . . . . . 800,000
Face value of term life insurance policy on Adam’s life . . . . . . . . . . . . . . . . . . . . . . . . . 2,000,000
Automobile in Adam’s name . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22,000

Other information includes the following:

1. Adam owned the life insurance policy, and his estate is the beneficiary.

2. Callie is the beneficiary of the retirement plan.

3. Adam willed $2 million of his stocks to Callie and the rest of his property to Zebulon.

4. Adam owed $13,200 on a car loan.

5. The estate’s administrative expenses were $32,000, and his funeral expenses were $8,000.

6. Assume that the estate paid state estate taxes of $45,000.

7. Adam made his only taxable gift, $6 million taxable amount, in December 2015 and paid all the gift taxes from an account solely in his name.

8. Assume the estate’s marginal income tax rate will be 35%.