On November 18, 2011, the Department of the Treasury issued proposed regulations1 withdrawing the proposed regulations issued April 25, 20082 which were designed to combat post-death maneuvering of value in utilizing the alternate valuation date approach to federal estate tax valuation.3 The issue had arisen because of the strategy employed in Kohler, Jr. v. Commissioner4 by which a corporate reorganization after death was used to reduce the value of the estate from $144.5 million to $47 million.