“Well”, said Snotnose, “you see, your father had a negative capital account in those real estate partnerships. That means that he took losses greater than what he contributed into the partnership. Further his carry-over losses were lost when he died. Because you did not receive a basis increase at his death due to Section 1022, you recognize ordinary income to the extent of his negative capital account.” “How much is that? asked Delicious. “About $50 Million. The rest is capital gain. But of course there is debt on the property of $50 Million” said the lawyer. “So what does all that mean?” asked Delicious