Following up on comments the Greystocke Project submitted two years ago,
to which the Treasury and IRS did respond by issuing a revenue ruling that does make the requested statement, that in general Code section 1014(a) does not afford an adjustment to basis in assets held in a "grantor" trust where the value of those assets is not includible in the gross estate of the deemed owner,
but subject to an exception that pretty much swallows the rule, so that in the typical case a taxpayer claiming a basis adjustment will not have to file a form 8275 disclosing a reporting position inconsistent with the ruling,
and they completely failed to deal with a 1985 revenue ruling that is the source of the problem.
to which the Treasury and IRS did respond by issuing a revenue ruling that does make the requested statement, that in general Code section 1014(a) does not afford an adjustment to basis in assets held in a "grantor" trust where the value of those assets is not includible in the gross estate of the deemed owner,
but subject to an exception that pretty much swallows the rule, so that in the typical case a taxpayer claiming a basis adjustment will not have to file a form 8275 disclosing a reporting position inconsistent with the ruling,
and they completely failed to deal with a 1985 revenue ruling that is the source of the problem.
| greystocke_project_comment_notice_2024-28_merged.pdf |
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