Generally, the income tax basis, for federal income tax purposes, of an asset included in the gross estate of a decedent (or otherwise passing from the decedent at death) is equal, under Section 1014(a), to its estate tax value (normally equal to the asset's fair market value ("FMV") on the date of death or, if it applies, the FMV on the alternate valuation date determined under Section 2032). This change-of-basis rule is subject to an important exception for income in respect of decedent ("IRD").
Jonathan G. Blattmachr and Mitchell M. Gans,
Planning for IRD after Elimination of the State Death Tax Credit, 33 Est. Plan. 3
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