So there are say 100 shares of stock in a $2mil Farm every time someone wants to transfer it to another family member they should be held accountable at $20K/share as if it was cash income?  Keeping in mind none of them can just go to Scottrade and get their $20K a share if they want.  We are talking closely held private companies not public widely held ones.  That would accelerate the breakup of Farms and Ranches in a matter of one generation.  Doesn't take much land these days to surpass the top exemption of estate or gift tax and not being able to take a 50% or more deduction in the transfer of paper shares (NO cash) would be hugely destructive.  Should these share holders ever liquidate they will then get bent over and taxed half a dozen ways, easily pushing 50% tax on a pure cash out and could be 80% if not handled properly. 

You want to really close up a loop hole, quit making the corporation 100% responsible for taxes should a stock holder trade their shares in for some property.  The Corp. takes that as income, even though all they are doing is getting  a paper stock and losing a tangible asset.