26 U.S.C. § 6324B — Special lien for additional estate tax attributable to farm, etc., valuation

(a) General rule. When an estate uses the special farm-valuation method for real property under section 2032A, the United States automatically gets a lien on that property. The lien equals the "adjusted tax difference" — the extra estate tax that would be owed if the special valuation were later disqualified. (b) Period of lien. This lien begins the moment the estate files its section 2032A election. It lasts until the related tax liability under section 2032A(c) is paid. It also ends if that liability becomes legally unenforceable through the passage of time. It ends as well once the Secretary is satisfied that no further tax liability can arise on that property. (c) Certain rules and definitions made applicable. Several procedural rules from the lien for deferred estate tax under section 6324A also apply here, as though this lien were created under that section. "Qualified real property" for this section also includes replacement property and exchange property obtained under section 2032A's later provisions. (d) Substitution of security for lien. The Secretary may allow the estate to post other security in place of this lien, under regulations the Secretary prescribes.

The record establishes that 26 U.S.C. § 6324B was added by Public Law 94–455, title XX, § 2003(b), enacted October 4, 1976, 90 Stat. 1861. The source credit further shows that the section was subsequently amended three times: by Public Law 95–600, title VII, § 702(r)(4), in 1978; by Public Law 96–222, title I, § 108(d), in 1980; and by Public Law 97–34, title IV, § 421(d)(2)(B), in 1981. These citations indicate a period of active refinement in the years immediately following enactment, followed by no further amendment activity reflected in this credit. Public Law 94–455 is commonly known as the Tax Reform Act of 1976, a major piece of federal tax legislation. The Act is generally understood to have made extensive changes across the estate and gift tax system, including the introduction of special-use valuation rules for certain farm and closely held business real property under section 2032A. Section 6324B appears connected to that broader reform, as it creates a lien mechanism tied to the additional estate tax that may become due if such specially valued property is later disposed of or ceases to be used for its qualifying purpose. Beyond this general connection to the 1976 Act's estate tax provisions, the record does not establish the specific legislative reasoning behind the particular lien mechanics, security-substitution provision, or the details added by the later 1978, 1980, and 1981 amendments. Any more specific account of congressional intent for those changes would be speculative.