The interest rate provided for is 9%.
The election of § 2032 (alternate valuation date)
$413,000 basis for gain and loss.
She makes gifts to family members to help her estate qualify under § 6166 (extension of estate tax payments relative to an interest in a closely held business).
Lacking any election by the trustee, Pamela’s basis in the asset is $20,000.
$40,000 by Antoinette and $80,000 by George
$200,000 ordinary income