If only Mr. Pohlad has survived until 2010, the federal estate tax would have been $0. George Steinbrenner died in 2010 -- zero federal estate taxes. As for the valuation issue, the Internal Revenue Code bases gift taxes and estate taxes on fair market value. Fractional interests are worth less in the real world and for tax purposes. A house may be worth $1 million, but a 1/3 interest in the same house might be worth less than $250,000, because a hypothetical buyer would not pay more than that for such interest. With few exceptions, buyers want 100%, or at least a controlling interest. Based on what is described in the article, this looks like legitimate estate planning, and generally these cases settle on terms that are favorable to the estate. I would also note that the Pohlads have lawyered up with John Porter, who many people (including me) believe is the best litigator in the country for cases like this.