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 Rev. Rul. 54-97

1954-1 C.B. 113

Sec. 1014

Full Text

Rev. Rul. 54-97

For the purpose of determining the basis under section 113(a)(5) of the Internal Revenue Code of property transmitted at death (for determining gain or loss on the sale thereof or the deduction for depreciation), the value of the property as determined for the purpose of the Federal estate tax shall be deemed to be its fair market value at the time of acquisition. Except where the taxpayer is estopped by his previous actions or statements, such value is not conclusive but is a presumptive value which may be rebutted by clear and convincing evidence. Cf. Rev. Rul. 54-10, p. 24.