Proposed Estate Tax changes for Wealthy Estates

The Obama Administration, faced with health care budget shortfalls , will be looking to boost tax revenues collectible on wealthy estates. 

One proposal, as cited by the Wall Street Journal article, is to allow only one valuation for a particular asset whether being gifted or whether inherited.  Its unclear how this rule will be applied in reality.  As the article states:

[t]hat is because the incentive is to undervalue items when paying the estate tax. But the incentive is to overvalue them when reporting gifts, so that the basis will be higher when calculating capital gains if the item is sold. Under the proposal, taxpayers would have to use the same value for both purposes.

Makes sense to me, but the actual impact of such a change on the average American estate will be minimal.  Also, the question arises on how such a valuation rule change would actually impact a single piece of property or a single taxpayer.  Yes, it closes a loophole, but maybe this loop isn't so big to make a difference in the amount of tax collected.

Either way, while the Treasury estimates that this change will collect more than $24B of the $60B it seeks to raise, it still will only impact "less than three-tenths of 1 percent of estates in any year".