Sam owns 500 acres of farmland. All of the following are requirements for the farmland to qualify for and retain special-use (current-use) valuation upon Sam's death except:

A)The farm must constitute at least 50 percent of Sam's gross estate (after certain adjustments for mortgages and liens).

B) Sam must have been a U.S. citizen or resident.

C) Sam or a family member must have owned the real property and used it as a farm for at least 5 of the 8 years immediately prior to Sam's death.

D) The special-use tax savings will not be recaptured as long as the qualified heir does not dispose of the property for at least 2 years following Sam's death.