US Code

Public Law 119-73 (01/23/2026)

26 U.S.C. § 6324B

Special lien for additional estate tax attributable to farm, etc., valuation

(a)

General rule

In the case of any interest in qualified real property (within the meaning of section 2032A(b)), an amount equal to the adjusted tax difference attributable to such interest (within the meaning of section 2032A(c)(2)(B)) shall be a lien in favor of the United States on the property in which such interest exists.

(b)

Period of lien

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 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 and definitions made applicable

(1)

In general

The rule set forth in paragraphs (1), (3), and (4) of section 6324A(d) shall apply with respect to the lien imposed by this section as if it were a lien imposed by section 6324A.

(2)

Qualified real property

For purposes of this section, the term “qualified real property” includes qualified replacement property (within the meaning of section 2032A(h)(3)(B)) and qualified exchange property (within the meaning of section 2032A(i)(3)).

(d)

Substitution of security for lien

To the extent provided in regulations prescribed by the Secretary, the furnishing of security may be substituted for the lien imposed by this section.

Pub. L. 94–455, title XX, § 2003(b)90 Stat. 1861Pub. L. 95–600, title VII, § 702(r)(4)92 Stat. 2939Pub. L. 96–222, title I, § 108(d)94 Stat. 228Pub. L. 97–34, title IV, § 421(d)(2)(B)95 Stat. 309(Added , , ; amended , , ; , , ; , , .)

Editorial Notes

Amendments

Pub. L. 97–341981—Subsec. (c)(2). defined “qualified real property” to include qualified exchange property (within the meaning of section 2032A(i)(3)).

Pub. L. 96–2221980—Subsec. (c). designated existing provisions as par. (1), substituted “The rule” for “The rules”, and added par. (2).

Pub. L. 95–6001978—Subsec. (b). substituted “qualified real property” for “qualified farm real property”.

Statutory Notes and Related Subsidiaries

Effective Date of 1981 Amendment

Pub. L. 97–34section 421(k)(3) of Pub. L. 97–34section 2032A of this titleAmendment by applicable with respect to exchanges after , see , set out as a note under .

Effective Date of 1980 Amendment

Pub. L. 96–222Pub. L. 95–600section 201 of Pub. L. 96–222section 32 of this titleAmendment by effective, except as otherwise provided, as if it had been included in the provisions of the Revenue Act of 1978, , to which such amendment relates, see , set out as a note under .

Effective Date of 1978 Amendment

Pub. L. 95–600section 702(r)(5) of Pub. L. 95–600section 2051 of this titleAmendment by applicable to estates of decedents dying after , see , set out as a note under .