Issue: A grantor sells an appreciating asset to an irrevocable grantor trust in return for a promissory note. If the trust converts to a non-grantor trust because he grantor dies while the note is still outstanding, does the grantor realize gain?

Chart Shows: Yes, the grantor realizes gain.

For More Information: See Carol A. Cantrell, “Gain Is Realized at Death,” Trusts & Estates, Feb. 2010, p. 20.