This guy needs to talk to an estate lawyer. With the different vehicles (family limited partnerships, discounts for lack of marketability) out there, I'd be willing to bet that they can legally avoid paying estate tax entirely.
If the owner has the foresight to die in 2009, there will be no estate tax anyway. ;^)
My wife is a CPA and does a lot of estate transfer and planning work. This one just cracks them up, in a shaking-your-head-at-the-idiocy sort of way. It really doesn't do much for the citizenry.