Assets held until death, other than for assets producing income in respect of decedent,1 generally receive a new income tax basis at death.2 The basis of income in respect of decedent items, by contrast, is not adjusted at death, under the theory that the income is too close to being earned.3 Income in respect of decedent assets carry over the decedent’s basis into the hands of the heirs or other successor to the decedent.4