Original issue discount (OID) is never treated as income in respect of a decedent because: 

 a. income that the decedent will not receive for more than ten years cannot be valued and thus is not treated as income in respect of a decedent 

b. OID is tax-exempt to the decedent and it retains its character in the hands of the beneficiary 

c. taxpayers are required to recognize such income as it is earned on a daily basis so there is never any earned but untaxed income from an OID instrument 

d. OID is not payable if the owner of the OID does not survive past the maturity date of the OID instrument and, thus, is not income in respect of a decedent