PUBLIC LAW 94-455—OCT. 4, 1976
90 STAT. 1 8 6 1
poses over a reasonable period of time under p r u d e n t management using traditional cropping patterns for the area, taking into account soil capacity, terrain configuration, and similar factors, " (B) The capitalization of the fair rental value of the land for farm land or closely held business purposes, " (C) Assessed land values in a State which provides a differential or use value assessment law for farmland or closely held business, " (D) Comparable sales of other farm or closely held business land in the same geographical area f a r enough removed from a metropolitan or resort area so that nonagricultural use is not a significant factor in the sales price, and " (E) Any other factor which fairly values the farm or closely held business value of the property. " (f) STATUTE OF LIMITATIONS.—If qualified real property is disposed of or ceases to be used for a qualified use, then— " (1) the statutory period for the assessment of any additional tax under subsection (c) attributable to such disposition or cessation shall not expire before the expiration of 3 years from the date the Secretary is notified (in such manner as the Secretary may by regulations prescribe) of such disposition or cessation, and " (2) such additional tax may be assessed before the expiration of such 3-year period notwithstanding the provisions of any other law or rule of law which would otherwise prevent such assessment.
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" (g) APPLICATION OF T H I S SECTION AND SECTION 6324B TO INTERESTS
IN PARTNERSHIPS, CORPORATIONS, AND T R U S T S. — The Secretary shall Regulations.
prescribe regulations setting forth the application of this section and section 6324B in the case of an interest in a partnership, corporation, or trust which, with respect to the decedent, is an interest in a closely held business (within the meaning of paragraph (1) of section 6166(b))." (b) SPECIAL L I E N. — Subchapter C of chapter 64 (relating to lien for taxes) is amended by inserting after section 6324A the following new section: "SEC 6324B. SPECIAL LIEN FOR ADDITIONAL ESTATE TAX ATTRIBUT- 26 USC 6324B. ABLE TO FARM, ETC., VALUATION. " (a) GENERAL RULE. — I n the case of any interest in qualified real property (within the meaning of section 2 0 3 2 A (b)), an amount equal Ante, p. 1856. to the adjusted tax difference attributable to such interest (within the meaning of section 2032A(c)(2)(B)) shall be a lien i n favor of the United States on the property in which such interest exists. " (b) PERIOD OF L I E N. — The lien imposed by this section shall arise at the time an election is filed under section 2032A and shall continue with respect to any interest in the qualified farm real property— " (1) until the liability for tax under subsection (c) of section 2032A with respect to such interest has been satisfied or has become unenforceable by reason of lapse of time, or " (2) until it is established to the satisfaction of the Secretary that no further tax liability may arise under section 2032A(c) with respect to such interest. "(c)
CERTAIN RULES MADE A P P L I C A B L E. — The rules set forth
in
paragraph s (1), (3), and (4) of section 6324A(d) shall a p p l y with respect to the lien imposed by this section as if it were a lien imposed by section 6324A.
Post, p. 1868.
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