2704(a)(1) would include the value of the lapsed rights in the father's estate.
2704(a) occurs because the lapsed right can no longer be reclaimed.
Thus, the lapsed right may be considered in valuing D's stock for estate tax purposes.
Thus, if an individual transfers an interest with a lapsing voting or liquidation right within three years of the individual's death, the right is considered to lapse at the individual's death, and the value of the lapsed right is included in the individual's gross estate.