debt shall be treated as a distribution from the SLDO account and any subsequent decrease in debt shall be taken into account as a reduction in distributions from the SLDO account or as a credit against tax (as the Secretary determines appropriate). (F) Any distribution from the SLDO account shall result in an increase in the taxable income of the taxpayer equal to the product of the estimated value of the distribution multiplied by the notional interest percentage at the time of the distribution. (G) A taxpayer may elect to pay liabilities under this subsection in advance and proper credit shall be provided for any such liabilities so paid in advance upon resolution of the SLDO account. (H) The Secretary shall establish a special valuation regime for purposes of determining the estimated value of any distribution of a non-tradable asset from a SLDO account. Such special valuation regime shall ensure valuation accuracy, minimize the potential for under-valuation, and minimize the potential for taxpayer gaming. Such regime may include the use of appraisers employed by the Secretary, formulaic valuations, or any other method designed to ensure valuation accuracy and minimize the potential for gaming. Any estimated value determined under such special valuation regime may be challenged by the taxpayer only upon a showing of clear and convincing error. In place of the standard due process safeguards, a taxpayer may opt to reject such special valuations (under rules and procedures to be determined by the Secretary) and instead maintain the non-tradable asset within a SLDO account. (I) If a taxpayer is subject to the requirements of this subsection with respect to any assets, such taxpayer shall remain subject to the requirements of this subsection (without regard to whether or not such taxpayer ceases to be an applicable taxpayer) until the SLDO account is resolved and all liabilities with respect to such SLDO account have been paid. For purposes of this subsection, an SLDO account shall be treated as resolved upon