Also adjust for depreciation allowed or allowable. Since this a farm, there are most likely depreciable assets. It is not clear if the brother was a life tenant of the farm or a beneficiary of the trust. If he was a life tenant, he would be allowed the depreciation per Section 1.167(h)-1. Then, after the farm reverts back to the trust, the adjusted basis of the assets in the hands of the brother would go to the trust per the Uniform Basis Rule of Section 1.1014-4.