Any comment brief or detailed is appreciated….

For 706 prep, how to handle alternate valuation for decedents IRA? Is alt value date same as date of death? is it the date that the account is retitled as beneficiary IRA? Is it like any other stock portfolio – valued based on interim sales and value of untouched assets six months later? What does otherwise disposed of mean?

I pulled a rev ruling from 1978 which indicates that assets passing by operation of law are deemed to be disposed of if those assets are not subject to estate claims. However, in researching this matter a few years ago, I got the impression that more recently than year 1978, that some experts argue that alt valuation is available; any thoughts on this issue?

FYI Code section 2032 and the regs seem to clearly indicate that any asset that is otherwise disposed of within six months is valued at date of dispostion….the term “…otherwise disposed of” per regs “comprehends all possible ways by which property ceases to form part of the gross estate’

Reg 20.2032-1(c)(2) & (3) seem to indicate that distribution does not take place until ‘separation of the property…so that it becomes unqualifiedly subject to the demand…of distributee…” that might be when the beneficiary account(s) are established???

Thanks in advance for any comments or any recommendations on where to find reading material