Sam's gross estate includes stock in Tern Corporation and Wren Corporation,valued at $700,000 and $900,000,respectively.At the time of Sam's death in 2009,the stock represented 27% of Tern's outstanding stock and 38% of Wren's outstanding stock.Sam's adjusted gross estate equals $4,400,000.Death taxes and funeral and administration expenses for Sam's estate total $700,000.Sam had a basis of $120,000 in the Tern stock and $300,000 in the Wren stock at the time of his death.None of the beneficiaries of Sam's estate own (directly or indirectly)any stock in Wren Corporation,but some of the beneficiaries own stock of Tern Corporation.Consider the following independent questions.

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