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I would consider converting the entire $700,000 into a Roth. It would get the taxes paid on the roth conversion out of the estate. I would at least use up the lower tax rates to convert to the roth. I would consider setting-up a limited partnership for the stocks. Have the taxpayer gift a 26% interest to the 2 beneficiaries taking minority interest and lack of marketability discounts. Then the estate value of the LP would get the minority interest discount.

Just a very quick take

Good luck and i hope every works out fine,

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