Par. 6. Section 1.6662-8 is added to read as follows:
(a) In general. Section 6662(a) and (b)(8) impose an accuracy-related penalty on the portion of any underpayment of tax required to be shown on a return that is attributable to an inconsistent estate basis.
(b) Inconsistent estate basis. In accordance with section 6662(k), there is an inconsistent estate basis to the extent that a taxpayer claims a basis, without regard to the adjustments described in § 1.1014-10(a)(2), in property described in paragraph (c) of this section that exceeds that property's final value as determined under § 1.1014-10(c).
(c) Applicable property. The property to which this section applies is property described in § 1.1014-10(b) that is reported or required to be reported on a return required by section 6018 filed after July 31, 2015.
(d) Effective/applicability date. Upon the publication of the Treasury Decision adopting these rules as final in the Federal Register , this section will apply to property described in § 1.1014-10(b) acquired from a decedent or by reason of the death of a decedent whose return required by section 6018 is filed after July 31, 2015. Persons may rely upon these rules before the date of publication of the Treasury Decision adopting these rules as final in the Federal Register .