Reference no: EM13144892

Janet Mason filed a 2008 gift tax return to report the gift on June 3, 2008, of closely held stock in Mason Meet Co., Inc. The tax return, which your firm prepared, reflected a value of $1,500 per share (determined by an appraiser) and a taxable gift of $1.1 million. This was Janet’s first taxable gift, and she exhausted her full unified credit of $345,800. On October 22, 2009, Janet’s father, Mason Meat’s CEO and founder, died unexpectedly at age 59. In addition, two months prior to her father’s death the firm had recalled much of its meet from distributors and supermarkets because of contamination in the meet plant. The meat plant closed for six weeks while the contamination problem was corrected. An appraiser valued the stock for her father’s estate at $1,000 per share. Janet would like for your firm to prepare an amended gift tax return and value her gift at $1,000 per share because of the decline in value resulting from the two events described. She would like to receive a refund of the gift tax she paid and have some of her unified credit restored. Prepare a memo that addresses whether Janet should be entitled to refund of the gift tax paid and restoration of some of her unified credit.