This is a great topic. So important to the dynamic of the Buffalo Bills. I am in insurance- the 1 thing not mentioned here yet is the unknown---> Ralph could easily have already covered his estate tax burden w/ life insurance. No sense in paying any tax by selling the team now. Get the step up at Basis at death, like you say. if they sell it for more than the fari mkt value, they will be happy to pay a little tax then as is more money in their pocket.
But w/ the insurance, all he would have paid is the insurance premium and he could have done that w/ a trust (ILIT) and using his beneficiaries and gift them each 13K x 2 (Ralph & wife) = 26K to lower estate value and to pay insurance. Thus when they pass, the estate tax is covered by the death benefit. No tax, just insurance premiums. The question is, what has Ralph done- we may never know. I assume he has handled this. Look at Miami & Washington. Both their teams changed ownership real fast w/ untimely deaths of their owners. My thinking is Ralph learned from past mistakes and took advantage of living long and locked up his legacy w/ some simple insurance planning.
Here's hoping for his family's sake, he didn't mis-manage his fortune like he has mis-managed his football team.