Before considering whether the section $2032$A special use valuation may be used, D$\text{'}$s entire

gross estate was valued at $$30$ million as of the date of his death. The gross estate was

comprised of the value of land which he had actively farmed for the past $20$ years and that

at his date of death was worth $$18$ million, and the value of heavy farming equipment

valued at $$4$ million. The remaining $$8\mathrm{.}0$ million is attributable to $D\text{'}$s home and other assets

such as stocks and bonds. Exactly six months following his date of death, and without

considering section $2032$A special use valuation, the land's market value decreased to $$17\mathrm{.}0$

million, although the value of all other assets remained the same. After considering section

$2032$A special use valuation, however, his land was worth $$11\mathrm{.}0$ million at his death and

$$7\mathrm{.}5$ million six months later. He devised his farm to his daughter who agreed to farm it for

the next ten years. Which of the following is a true statement?

Assuming a $2032$ election is made, the land qualifies for valuation under section $2032$A$,$ and its

special use valuation is $$7\mathrm{.}5$ million, D$\text{'}$s executor may report the land's value in his gross estate at

$$7\mathrm{.}5\mathrm{.}0$ million.

The estate may not elect section $2032$ A valuation because $D$ left the farm to his daughter.

Special use valuation under section $2032$A cannot be used in conjunction with the alternate

valuation regime under section $2032$ so there is no point in trying to determine the value of the

gross estate six months after D$\text{'}$s death.

Assuming D$\text{'}$s executor is entitled to elect section $2032$A special use valuation and it turns out D$\text{'}$s

daughter sells the farm after five years, she $($and not D$\text{'}$s estate$)$ will be primarily responsible for the

recaptured estate tax whether or not a section $2032$ election is made