[jeremy_arnold]

I just mean that so far as the invention/calibration of the taxes, the idea was that a high estate tax would offset the reset of capital gains. I don't have a strong position on whether the laws do this well or make full sense etc.

Though I'll note that the scenario you pose never really happens. A billionaire isn't going to cash out a billion dollars of stock just to have cash to sit on. They're either doing it to spend in on consumption (nothing to inherit anyway) or to buy a different asset that would itself have capital gains assigned.