[Code of Federal Regulations]
[Title 26, Volume 11]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.1014-7]

[Page 52-53]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.1014-7  Example applying rules of Sec. Sec. 1.1014-4 through 
1.1014-6 to case involving multiple interests.

    (a) On January 1, 1950, the decedent creates a trust to pay the 
income to A for life, remainder to B or his estate. The trust instrument 
provides that if the decedent should survive A, the income shall be paid 
to the decedent for life. The decedent, who died on January 1, 1955, 
predeceases A, so that, due to the operation of the estate tax, only the 
present value of the remainder interest is included in the decedent's 
gross estate. The trust consists of an apartment building with a basis 
of $30,000 at the time of transfer. Under the trust instrument the 
trustee is required to maintain a reserve for depreciation. During the 
decedent's lifetime depreciation is allowed in the amount of $800 
annually. At the time of the decedent's death the value of the apartment 
building is $45,000. A, the life tenant, is 43 years of age at the time 
of the decedent's death. Immediately after the decedent's death, the 
uniform basis of the entire property under section 1014(a) is $32,027; 
A's basis for the life interest is $15,553; and B's basis for the 
remainder interest is $16,474, computed as follows:

Step 1. Uniform basis (adjusted) immediately prior to
 decedent's death:
  Basis at time of transfer...................................   $30,000
                             less
  Depreciation allowed under section 1016 before decedent's        4,000
   death ($800 x 5)...........................................
                                                     -----------
                                                                  26,000
Step 2. Value of property included in decedent's gross estate:
  0.40180 (remainder factor, age 43) x$45,000 (value of entire   $18,081
   property)..................................................
Step 3. Uniform basis of property under section 1014(a),
 before reduction required by section 1014(b)(9):
  Uniform basis (adjusted) prior to decedent's death..........    26,000
  Increase in uniform basis (determined by the following           7,634
   formula)...................................................
Increase in uniform basis (to be determined) $19,000 (total
 appreciation, $45,000-$26,000)]=
$18,081 (value of property included in gross estate) $45,000
 (value of entire property)]
                                                     -----------
                                                                  33,634
Step 4. Uniform basis reduced as required by section
 1014(b)(9) for deductions allowed prior to death:
  Uniform basis before reduction..............................   $33,634
                             less
  Deductions allowed prior to decedent's death--taken into         1,607
   account under section 1014(b)(9) (determined by the
   following formula).........................................
Prior deductions taken into account (to be determined) $4,000
 (total deductions allowed prior to decedent's death)]=
$18,081 (value of property included in gross estate) $45,000
 (value of entire property)
                                                     -----------
                                                                  32,027
Step 5. A's basis for the life interest at the time of the        15,553
 decedent's death, determined under section 1015: 0.59820
 (life factor, age 43) x $26,000
Step 6. B's basis for the remainder interest, determined under
 section 1014(a): Basis prior to the decedent's death:
  0.40180 (remainder factor, age 43) x $26,000................    10,447
                             plus
  Increase in uniform basis owing to decedent's death:
    Increase in uniform basis.......................    $7,634

[[Page 53]]


                        plus
    Reduction required by section 1014(b)(9)........     1,607  ........
                                                     ----------
                                                      ........     6,027
                                                               ---------
                                                      ........    16,474


    (b) Assume the same facts as in paragraph (a) of this section. 
Assume further, that following the decedent's death depreciation is 
allowed in the amount of $1,000 annually. As of January 1, 1964, when 
A's age is 52, the adjusted uniform basis of the entire property is 
$23,027; A's basis for the life interest is $9,323; and B's basis for 
the remainder interest is $13,704, computed as follows:

Step 7. Uniform basis (adjusted) as of January 1, 1964:
  Uniform basis determined under section 1014(a), reduced as     $32,027
   required by section 1014(b)(9).............................
                             less
  Depreciation allowed since decedent's death ($1,000 x 9)....     9,000
                                                               ---------
                                                                  23,027
Step 8. Allocable share of adjustment for depreciation
 allowable in the nine years since the decedent's death:
                         A's interest
  0.49587 (life factor, age 52) x$7,200 ($800, depreciation        3,570
   attributable to uniform basis before increase under section
   1014(a), x9)...............................................
                         B's interest
  0.50413 (remainder factor, age 52) x$7,200 ($800,                3,630
   depreciation attributable to uniform basis before increase
   under section 1014(a), x9).................................
                             plus
  $200 (annual depreciation attributable to increase in            1,800
   uniform basis under section 1014(a)) x9....................
                                                               ---------
                                                                   5,430
Step 9. Tentative bases of A's and B's interests as of January
 1, 1964 (before adjustment for depreciation).
                         A's interest
  0.49587 (life factor, age 52) x$26,000 (adjusted uniform        12,893
   basis immediately before decedent's death).................
                         B's interest
  0.50413 (remainder factor, age 52) x$26,000 (adjusted           13,107
   uniform basis immediately before decedent's death).........
                             plus
  Increase in uniform basis owing to inclusion of remainder in     6,027
   decedent's gross estate....................................
                                                               ---------
                                                                  19,134
Step 10. Bases of A's and B's interests as of January 1, 1964.
                               A
  Tentative basis (Step 9)....................................    12,893
                             less
  Allocable depreciation (Step 8).............................     3,570
                                                               ---------
                                                                   9,323
                               B
  Tentative basis (Step 9)....................................    19,134
                             less
  Allocable depreciation (Step 8).............................     5,430
                                                               ---------
                                                                  13,704