(2) Definitions For purposes of paragraph (1)— (A) Appreciated property The term “appreciated property” means any property if the fair market value of such property on the day it was transferred to the decedent by gift exceeds its adjusted basis. (B) Treatment of certain property sold by estate In the case of any appreciated property described in subparagraph (A) of paragraph (1) sold by the estate of the decedent or by a trust of which the decedent was the grantor, rules similar to the rules of paragraph (1) shall apply to the extent the donor of such property (or the spouse of such donor) is entitled to the proceeds from such sale.
26 USC § 1014(e)(2)
None identified. Default scope is assumed to be the entire title.