What is the test for determining whether the estate of a deceased has a right to receive income received after death?

The results in Steffen are consistent with the real issue in this case: what was the "income in respect of the decedent" pursuant to 26 U.S.C. S 691? To be considered income in respect of the decedent, the decedent must have had a right to receive the income at the time of his or her death. See Estate of Peterson v. Commissioner, 667 F.2d 675, 679 (8th Cir. 1981). As the court noted in that case:

Although it is pertinent to inquire whether the income received after death

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