Step-Up at Death but Not for Income,

Abstract

The article argues that the definition of property for the purposes of the Internal Revenue Code, section 1014 (step-up in basis at death) should include only capital interests and that ordinary income items – including compensation, things made or improved by the decedent, and inventory – should not get a step-up in basis at death. This proposal is the second of three Shelf Projects designed to prune back the basis step-up under section 1014.