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IRS withdraws and reproposes rules (REG-112196-07) that would allow estates to use a beneficial six-month alternate valuation date more broadly. The rules would allow estates to use the alternate valuation date in some cases where property is exchanged in reorganizations, mergers, and similar corporate deals. They also would permit the six-month date to be used in some cases involving distributions from business entities, bank accounts, or retirement trusts. Neither of these exceptions were allowed under the original proposed rules. Under those rules, estates could use the beneficial alternate valuation method only if they experienced a reduction in gross value after the decedent's death due to market conditions and not due to other post-death events.
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