Form 706 - United States Estate (And Generation-Skipping Transfer) Tax Return (Page 10 of 41) in pdf

Form 706 (Rev. 8-93)

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 Service with any requested information concerning the property.

To notify the 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

Form 706 - United States Estate (And Generation-Skipping Transfer) Tax Return Page 10

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