Under IRC Section 1014(b), seven types of property are considered to have been acquired from or to have passed from the decedent for purposes of IRC Section 1014(a), （税法规定，七类财产被认为是符合1014(a)的要求） including: (1) property acquired by bequest, devise or inheritance, or by the decedent's estate from the decedent; (2) property where a decedent had, while alive, the power to (a) revoke or (b) amend the trust or hold a power to appoint the assets; (3) property transferred under a testamentary general power of appointment; (4) community property; (5) property that is included in a decedent's gross estate under the provisions of Chapter 11; and (6) property included in a surviving spouse's estate due to a marital deduction allowed in the first-to-die spouse's estate.
你说的财产符合（6）。以下分析讲IRS为什么认为某种生前转入不可变信托的财产不符合1014（a)的规定。你可以自己按照逻辑看，就是（b)(1)....(7)一个个分析。新的规定不适用于你的情况。
The IRS first found that the assets were not "bequeathed," "devised" or "inherited" within the meaning of IRC Section 1014(b)(1) when the decedent died. The IRS based its analysis on previous case law and legislative history and found that the property transferred in trust before the decedent's death was not bequeathed or inherited because it did not pass either by will or intestacy.
The IRS then found that the assets did not fall within any of the remaining types of property listed in IRC Section 1014(b).
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