If the executor of the estate of any decedent transfers to a qualified heir (within the meaning of section
2032A
(e)(1)) any property with respect to which an election was made under section
2032A, then gain on such transfer shall be recognized to the estate only to the extent that, on the date of such transfer, the fair market value of such property exceeds the value of such property for purposes of chapter 11 (determined without regard to section
2032A).