And while we are on the subject of the IRS...................

IRS Grabs $388 Million From Billionaire Davidson Estate

Given that the Court entered a stipulated decision (and therefore there will be no appeal)  as opposed to a full opinion all we can take from this case at this point is that the IRS has valuations square in their cross hairs.  What we are left to wonder is how the valuations were so far off the mark.  The Forbes reporter makes an important point that even those taxpayers who file to preserve portability must exercise caution in the valuations.