<cmiller[at]boascpas.com> wrote in message
news:77dbc3b0-25ff-484b-9174-c2bb32bbbf2a[at]u18g2000pro.googlegroups.com...
- quote -

This is a question we've debated in the T&E department of my law firm.
You have to use date of distribution values to fund the pecuniary bequest
since Chapter 13 requires funding of such bequests using the principles of
Rev. Proc. 64-19. So both gain or loss would be realized except for the
prohibition against recognizing loss on a related party transaction. Since
no loss ican be recognized, we've taken the position that a basis step-down
to
date of distribution value is not required and that the 706 value carries
over.
Thus far none of our clients have been audited with respect to basis
adjustments,
and I haven't seen any PLRs or TAMs one way or the other.
Jon Gallo
Los Angeles

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Administrative trust to fund pecuniary amount to GST trust with stocks
that have declined since Form 706 alternate valuation date. Funding
loss cannot be deducted on admin trust ITR. What happens to it? Is
it lost or does the 706 basis of the stocks carryover to the GST
trust?

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<< ------------------------------------------------------- > << The foregoing was not intended or written to be used, > << nor can it used, for the purpose of avoiding penalties > << that may be imposed upon the taxpayer. > << > << The Charter and the Guidelines for submitting posts > << to this newsgroup as well as our anti-spamming policy > << are at www.asktax.org. > << Copyright (2007) - All rights reserved. > << ------------------------------------------------------- >