Form 706 - United States Estate (And Generation-Skipping Transfer) Tax Return Page 10
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46Form 706 (Rev. 11-01)
Part 3. Agreement to Special Valuation Under Section 2032A
Date of Death
Decedent’s Social Security Number
Estate of:
There cannot be a valid election unless:
● The agreement is executed by each and every one of the qualified heirs, and
● The agreement is included with the estate tax return when the estate tax return is filed.
We (list all qualified heirs and other persons having an interest in the property required to sign this agreement)
,
being all the qualified heirs and
,
being all other parties having interests in the property which is qualified real property and which is valued under section 2032A of the
,
Internal Revenue Code, do hereby approve of the election made by
,
Executor/Administrator of the estate of
pursuant to section 2032A to value said property on the basis of the qualified use to which the property is devoted and do hereby enter
into this agreement pursuant to section 2032A(d).
The undersigned agree and consent to the application of subsection (c) of section 2032A of the Code with respect to all the property
described on line 2 of Part 2 of Schedule A-1 of Form 706, attached to this agreement. More specifically, the undersigned heirs expressly
agree and consent to personal liability under subsection (c) of 2032A for the additional estate and GST taxes imposed by that subsection
with respect to their respective interests in the above-described property in the event of certain early dispositions of the property or early
cessation of the qualified use of the property. It is understood that if a qualified heir disposes of any interest in qualified real property to
any member of his or her family, such member may thereafter be treated as the qualified heir with respect to such interest upon filing a
Form 706-A and a new agreement.
The undersigned interested parties who are not qualified heirs consent to the collection of any additional estate and GST taxes imposed
under section 2032A(c) of the Code from the specially valued property.
If there is a disposition of any interest which passes, or has passed to him or her, or if there is a cessation of the qualified use of any
specially valued property which passes or passed to him or her, each of the undersigned heirs agrees to file a Form 706-A, United States
Additional Estate Tax Return, and pay any additional estate and GST taxes due within 6 months of the disposition or cessation.
It is understood by all interested parties that this agreement is a condition precedent to the election of special use valuation under section
2032A of the Code and must be executed by every interested party even though that person may not have received the estate (or GST)
tax benefits or be in possession of such property.
Each of the undersigned understands that by making this election, a lien will be created and recorded pursuant to section 6324B of the
Code on the property referred to in this agreement for the adjusted tax differences with respect to the estate as defined in section
2032A(c)(2)(C).
As the interested parties, the undersigned designate the following individual as their agent for all dealings with the Internal Revenue Service
concerning the continued qualification of the specially valued property under section 2032A of the Code and on all issues regarding the
special lien under section 6324B. The agent is authorized to act for the parties with respect to all dealings with the Service on matters
affecting the qualified real property described earlier. This authority includes the following:
● To receive confidential information on all matters relating to continued qualification under section 2032A of the specially valued
real property and on all matters relating to the special lien arising under section 6324B.
● To furnish the Internal Revenue Service with any requested information concerning the property.
● To notify the Internal Revenue Service of any disposition or cessation of qualified use of any part of the property.
● To receive, but not to endorse and collect, checks in payment of any refund of Internal Revenue taxes, penalties, or interest.
● To execute waivers (including offers of waivers) of restrictions on assessment or collection of deficiencies in tax and waivers of
notice of disallowance of a claim for credit or refund.
● To execute closing agreements under section 7121.
(continued on next page)
Schedule A-1— Page 10
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