Jane is the founder of Citron Corporation and owns all of its stock, both common and preferred. The preferred stock is noncumulative and possesses no preferential rights as to liquidation. In 1996 and when the common stock has a value of $1,200,000, Jane gives it to her adult children. She retains the preferred stock which, at this time, has a value of $300,000. In 2011, Jane dies. Values on the date of death are: $3,000,000 for the common stock and $500,000 for the preferred.

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