Trustee wants to distribute a residential rental from a trust to a beneficiary.  This beneficiary is am adult man who is competent but irresponsible, apathetic, often unaccountable and doesn't have a source of earnings.  She wants to deed it to him. There is no mortgage.  The FMV is 650K. The carryover basis is 430K. In her mind there exists the possibility in the near future that the beneficiary would sell it but have no money to pay taxes.  And he Is the trustee doing the best thing?  Would you advocate the 643(e) election by the trust to tax it in order to step up the basis?  This action could mean no tax on a future sale as gain would likely be less than the 250K exclusion.  Is she best advised to seek the consultation of an attorney?