mr. speaker , i yield myself 5 minutes .  mr. speaker , it is a privilege to carry this debate today on behalf of the minority , and a privilege to participate with the gentleman from missouri , who is one of my favorite members of the house .  he has presented his side very well .  he asked relative to a number of estates , would they be covered under the pomeroy substitute ?  well , i believe that a number of them would have their estate tax problems completely eliminated , because we take the exemption and we double it .  we go from today , a joint estate at $ 3 million , and we say , if you have a joint estate of $ 6 million , no estate tax .  we , like 2009 , take that up to $ 7 million in a joint estate circumstance .  so as to the question he asked , i do not know the particulars of those cases , but i expect that a number , if not all of them are covered , because 99.7 percent of the estates in this country are under that amount .  but there is a feature of the majority proposal that is not represented in our substitute , and i want to talk about it right now , and this involves the imposition of capital gains liability at the handling of an estate under the majority bill .  i can just imagine members in the majority , some of them that might have signed that `` no new tax '' pledge that was going around last congress , just wringing their hands because they are about to vote for a tax increase , a tax increase in the form of capital gains taxation on estates .  section 541 of the bill that the majority proposal would make permanent reads this way : termination of step-up in basis at death .  tax legalese , but what does it mean ?  it means new capital gains and capital gains if you have an estate that exceeds that 1.3 gross value .  you have a reporting commitment that attaches at 1.3 gross value for estate .  you know , it is the darndest tax bill i ever saw .  because , while they talk about tax relief , they are hurting more than they are helping .  i direct you to this chart .  number of estates today with capital gains issue , zero ; and that is because the taxable basis in the property is established at time of transfer in an estate .  no capital gains .  what happens under their proposal ?  well , we know that there are 71 , 000 estates in the year 2011 that are likely to have reportable amounts , in other words , gross valuation over $ 1.3 million .  some will have a capital gains issue they have to pay .  some will not .  but they are all going to have to report with the irs .  and this report is something else .  it means going back in and trying to establish what the value of the property was at the time mom and dad acquired it .  it is a nightmare .  and that is well-established in the congressional record .  because i have here the hearing , i have here the ways and means record at the time the committee considered testimony to repeal the carryover basis , the very provision they want to re-establish in tax law .  you see , it passed once before , in 1976 .  it was delayed from implementation and then repealed retroactively because of its consequences .  here is what some very interesting participants had to bring to the committee .  carryover basis fosters an insidious bias against farmers and ranchers .  carryover basis calculations for land , buildings , machinery , livestock and timber have been described as , at best , potential nightmares .  trying to establish what the taxable basis on this is , which their law would require , is a nightmare .  so says the american farm bureau in their 1979 testimony .  the cattlemen 's association , one touted as one of these that want to re-establish capital gains on estates , they say , because of its complexity , carryover base is impossible to comply with .  it will increase the tax burden and compound the illiquidity of estates of farmers , ranchers and other family business operators who sell inherited property in the normal course of business , and i quote , and find it in the record from the national cattlemen 's association .  nfib also states , i strongly urge you , as an individual and as a taxpayer and as one who professionally and through an association represents small business people , repeal the carryover basis .  so says the national federation of independent business , the very group that they have cited as trying to re-establish carryover basis in the tax code and put capital gains back on estates .  we have been here before .  we do not want to do it again .  do you not understand , voting for the repeal bill brings a new bill , a capital gains bill , and a capital gains bill to thousands that have no estate tax consequence ?  so if you want to cast a vote this afternoon for a tax relief proposal , vote the pomeroy substitute .  no capital gains in the pomeroy substitute .  mr. speaker , i reserve the balance of my time .  