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accrual adjusted gross income aggregate alternative tax amount bequest Brookings Institution capital asset definition capital gains deduction capital gains tax capital gains treatment capital losses carry-over of basis changes computation constructive realization cost cumulative averaging death decedent defer depreciation dividends economic eliminate equity estimates exemption fiduciaries gain or loss gains and losses gains taxation holding period incentive included income class income tax Income Tax Returns increase Individual Income Tax Internal Revenue Code Internal Revenue Service investor lifetime long-term capital gains long-term gains marginal tax rates ment offset ordinary income percent portfolio preferential capital gains present law present value presumptive realization problem proposed proration provisions real estate realized gains reduce reported roll-over sales of capital Section short-term losses Table tax avoidance tax liability tax payment tax structure tax treatment taxable income taxpayer tion trade or business transfer treatment of capital U.S. Treasury Department unrealized gains yield