This article explores the impact on the estates of decedent partners and LLC members of the IRS amendments to the section 751 regulations that were promulgated in late 1999. Generally, the death of the partner or LLC member steps the estate's or other successor's basis in the partnership interest up to fair market value. When the estate sells, even though the selling price reflects that same fair market value, section 751(a) requires recognition of ordinary income to the extent that there are ordinary income assets in the partnership. Before the regulations were amended, the mechanics of computing the ordinary income permitted the estate to use one of two methods to cushion itself against ordinary income, namely, the partnership's section 754 election to generate a section 743(b) basis adjustment to the ordinary income items or the estate's section 732(d) election to generate the equivalent of the section 743(b) basis adjustment. The mechanism split amount realized and overall adjusted basis into an ordinary income and a capital gain portion, and it specified that the adjusted basis was split by making reference to the adjusted basis the ordinary income items would have had if they were distributed to the estate or other successor selling the partnership interest. This deemed distribution is what permitted the invocation of section 732(d). Under the new regulations, there is no splitting of amount realized and adjusted basis. Instead, the ordinary income to the estate or other successor selling the interest is the ordinary income that would be allocated to the estate if the partnership sold its ordinary income assets for fair market value. This approach closes the door to the section 732(d) election. It leaves the section 754 election as the sole solution, and thus puts a premium on the estate successfully persuading the partnership to make the section 754 election. The authors propose several possible refinements to the new regulations to eliminate this trap for the unwary.