§ 2001 Definition

This rule explains what the word "fiduciary" means in this part of the law. Normally, a fiduciary is someone officially appointed to handle a deceased person's estate, like an executor or administrator. But this rule expands that meaning for tax purposes.

If no one has been officially appointed yet to manage the estate, the law still needs someone to be responsible for reporting and handling estate taxes. So this rule says that anyone who actually holds or controls property that belongs in the deceased person's taxable estate counts as a "fiduciary" too, even without a formal appointment. This includes property counted under specific state tax law sections.

In simple terms, this means you cannot avoid tax responsibilities just because no one has been formally named to run the estate yet. If you have possession or control of estate property, the law can treat you as the person in charge for tax reporting purposes.