Wow, I posted this yesterday afternoon and came in this morning to see I got flamed.
Tbone, you are incorrect. Ralph's wife would receive a step up in basis. I never said she would avoid estate tax on the value of the team (or the cash if she sold the team), but she absolutely would not pay income tax on any capital gains unless the team appreciated further from the date of death value if she sold it. You are confusing two entirely separate parts of the tax code (basis rules versus estate taxes). And it is a marital deduction, not a marital exemption. Maybe that is what is confusing you. I don't have time to give you all the citations, so in the immortal words of Marv Levy "look it up Thurman". You may want to be a little more careful (or sure of your facts) when accusing someone of committing mass malpractice, whatever that is.