the net appreciation in value of any property is the amount by which (if any) the fair market value of the property exceeds the decedent’s adjusted basis as of the date of the decedent’s death. (4) Special rules for certain property For purposes of determining net appreciation in value of property, in lieu of fair market value, the following shall be used: (A) In the case of an election under 2032, the property value at the applicable valuation date prescribed by such section. (B) In the case of an election under section 2032A, the property value determined under such section. (C) To the extent of the applicability of the exclusion described in section 2031(c), the basis in the hands of the decedent. . (c) Conforming amendments (1) Section 1014(d) of such Code is amended by striking under subsection (a), such basis (determined before the application of this subsection) and inserting under this section (determined without regard to this subsection), such basis . (2) Section 1014(e) of such Code is amended by inserting before the period at the end the following: and subsection (g) shall not apply to such property . (d) Effective date The amendments made by this section shall apply to the estates of decedents dying after December 31, 2019. 4. Tax treatment of contributions of property to private foundation (a) In general Part IV of subchapter P of the Internal Revenue Code of 1986 is amended by adding at the end the following new section: 1261. Treatment of contributions of property to private foundation (a) In general Any property contributed by a taxpayer to a private foundation shall be treated for purposes of this title as sold by the taxpayer on the date of such contribution for its fair market value. (b) Determination and recognition of gain and loss In the case of any sale for the taxable year under subsection (a)— (1) this subchapter shall be applied separately with respect to all gains and losses from such sales, (2) losses shall be allowed only to the extent of gains, and (3) the tax imposed by this