On April $3,2024,$ Dayton filed a $2023$ gift tax return to report a gift of closely held stock in Perrin Chicken Farm, Inc. made on December $27,2023.$ The gift tax return, which your firm prepared, reflected a value of $$2,200$ per share $($determined by an appraiser$).$ This was Dayton$$s first taxable gift, and it exhausted his full $2023$ unified credit and required the payment of gift tax. On August $28,2024,$ Dayton$$s mother, Perrin Chicken Farm$$s CEO and founder, died unexpectedly at age $68.$ In addition, three months prior to his mother$$s death, the company recalled much of its chicken from supermarkets because of contamination in the chicken processing plant. The chicken farm closed for two months while the plant was decontaminated. An appraiser valued the stock for Dayton$$s mother$$s estate at $$1,800$ per share. Dayton wants your firm to prepare an amended gift tax return and value his gift at $$1,800$ per share because of the decline in value resulting from these two events. He would like to receive a refund of the gift tax he paid. Is Dayton$$s request justified? Write a client letter to Dayton Perrin $(1234$ University Ave., Lubbock, TX $79409).$ Your letter should summarize the relevant portions of $2512,$ Reg. $25\mathrm{.}2512-2($f$),$ and Okerlund v$.$ U$.$S$.,(2004,$ CA Fed Cir$)365$ F$3$d $1044.$