The IRS announced in Revenue Ruling 2023-2, that assets in a grantor trust which are not included in the grantor’s gross estate will not be entitled to a basis adjustment under Section 1014 at the grantor’s death. The taxpayer is questioning that position. Spouses created a joint grantor trust with community property and divided the trust into separate trusts representing the contributions of each grantor at the first spouse’s death. Belmont Investments, LLC. v. Commissioner, Tax Court Docket No. 14039-25 (Petition filed October 3, 2025).