Decedent’s basis in assets

This is off the topic of IRAs but I cannot find an authoritative answer and wonder if someone can help?

Could you tell me if you are aware of a rule that says that “step up”occurs AFTER midnight on the decedent’s date of death. If assets are sold on the same day as the date of death there is no step-up and capital gains may be recognized. I heard this from a bank trust officer, but need some authority.

Thanks!



I understand that some trust departments use a rule like this for their calculations but the Internal Revenue Code uses the average of the high and low on the date of death.



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