In 1980, Jonathan leased real estate to Jay Corporation for 20 years. Jay Corporation made significant capital improvements to the property. In 2000, Jay decides not to renew the lease and vacates the property. At that time, the value of the improvements is $900,000. Jonathan sells the real estate in 2010 for $1,300,000 of which $1,000,000 is attributable to the improvements. How and when is Jonathan taxed on the improvements made by Jay Corporation?

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