Tacked and Split Holding Periods:
1. You can get a one-year holding period for a piece of property by actually holding it that long. Alternatively, you can get it by tacking. A deemed holding period may be added (‘tacked on’) to the taxpayer’s actual holding period of an asset. Look at 1223:
a. 1223(2). If your mom gives you 1000 shares of IBM stock, you have a carryover basis under 1015 – i.e., your basis is the same as mom’s. Further, the time that mom held the stock is tacked on to the time that you actually held the stock.
b. 1223(11). If you get a baseball glove from a dead person, your basis is determined by 1014 – i.e., your basis is the value of that baseball glove at the date of the dead person’s death. Further, I’ll be treated as having held the property for the long-term holding period regardless of how long I or the dead person held it. Automatic LTKG holding period for people who pluck the tail feathers of dead folks.
2. Sale or Exchange of Multiple Assets
a. When more than one asset is sold or exchanged in one transaction, the holding period for each asset must be determined.
b. Dunigan v. Burnet: fixtures on real property do not take on the holding period of the land.
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