The alternate valuation date is an election.
Per Section 2032, the election to use the alternate valuation date can only be made if (a) it decreases the value of the gross estate, and (b) it decreases the amount of estate tax owed.
Since there would generally be no federal estate tax owed unless the estate exceeded the $11.7 million (for 2021) lifetime exemption, very few estates can elect the alternate valuation date.
