Ezel / IRS Rulings / 201202029

CCA 201202029: CCA addresses property acquired from a decedent

Number
201202029
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Basis Rules Applicable to the Estates of Decedents Dying in 2010
Topics
Property transactions and exchanges
Code sections
§ 1022
Ruling dated
December 9, 2011
Publicly released
January 13, 2012
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2012, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2012
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advice briefly addressed which assets are treated as “acquired from the decedent” for purposes of IRC section 1022(e). The advice pointed to Revenue Procedure 2011-41 as the relevant IRS guidance. The short memorandum does not state a broader conclusion beyond that reference.

Ruling snapshot

  • Question: What does “acquired from the decedent” mean for purposes of IRC section 1022(e)?
  • Outcome: Advice given
  • Key authorities: IRC § 1022(e); Rev. Proc. 2011-41

Full text (IRS public release)

ID: CCA-129114-11 Number: 201202029
Release Date: 1/13/2012
Office: ------------
UILC: 1022.00-00

From: -------------
Sent: Friday, December 9, 2011 11:49 AM
To: --------------------
Cc:
Subject: Another question

I just left you a voicemessage. Also, Rev. Proc. 2011-41 explains what assets are "acquired from the
decedent' for purposes of section 1022(e).

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace