This is going to pass because tens of thousands of businesses are slated to change hands as a generation of owners pass on. Existing estate taxes and this proposed rule will create a tax windfall for USGOV that will make up for years of bad legislation and policy. The unintended consequence of this rule is that even more businesses will not be able to afford the tax liability and the will sell to businesses who can killing good paying jobs for tens of thousands of Americans. Its inevitable, this rule is coming.