Handling and disposing of assets producing income in respect of decedent to avoid recognition of gain has long posed a problem. With items of income in respect of decedent, income uncollected at death is later subjected to income taxation to someone other than the decedent, for example, an estate, heir or beneficiary. If income in respect of decedent items are distributed by the estate, the items generally remain subject to income tax and are not subject to the trust rules allowing a deduction for amounts paid or credited to a beneficiary.
Harl, Neil E.
"Avoiding Recognition of Gain in Disposing of IRD Assets,"
Agricultural Law Digest: Vol. 13
, Article 1.
Available at: http://lib.dr.iastate.edu/aglawdigest/vol13/iss23/1