Because of their peculiar income tax character, items of income in respect of decedent1 require careful planning attention, particularly with respect to post-death dispositions.2 With IRD assets not receiving a new income tax basis at death,3 the pre-death basis carries over to the estate or heirs with the gain taxable to the estate, the heirs, a beneficiary or a specific or residuary legatee.4 The income recognition event can lead to substantial income tax liability inasmuch as the income tax basis is often zero for the more common IRD items.5