This notice provides guidance with regard to the time and manner in which the executor of the estate of a decedent who died in 2010 elects to have the provisions of section 1022 of the Code apply to determine a recipient’s basis in certain property deemed acquired from the decedent. This notice also provides guidance with respect to generation-skipping transfers (GSTs) and transfers that have GST potential that occurred during 2010.

This procedure provides optional safe harbor guidance to the executor of the estate of a decedent who died in 2010 and elects to have the provisions of section 1022 of the Code apply to determine a recipient’s basis in certain property acquired from the decedent.