This bill treats property transferred by gift or upon the death of a decedent as sold at its fair market value (thus requiring recognition of gain realized over the property's basis). Under current law there is a step up in basis of such property which allows for an exclusion of gain for gifts and estate property. The bill allows an exception to this fair market value rule for U.S. citizen spouses, charities, and certain tangible property. The bill allows a taxpayer an exclusion from income for up to $1 million (indexed for inflation) in gain resulting from transfers at death. The bill imposes certain information reporting requirements for gifts or bequests subject to this bill's fair market value rule. It also allows taxpayers to pay any tax due in two or more, but not more than seven, equal installments.