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IRS National Office: Don't Discount Estate Tax Value of IRAs Due to Income Taxes or Marketability (PDF)
Internal Revenue Service [IRS] 
[Official Guidance] Nov. 26, 2002
6 pages; released 11/22/02. Excerpt: Appraisal Firm hired by Decedent's executor appraised the IRAs at $b. This value reflects an aggregate c% discount for the potential income tax payable by the beneficiaries on IRA distributions, delays that might occur between the IRA custodian's receipt of a request for distribution and actual payment of distributions, and prohibitions on the transfer or the assignment of the accounts prior to distribution to the beneficiary.
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