Part III. Agreement to Special Valuation Under

Section 2032A The agreement to special valuation is required under sections 2032A(a)(1)(B) and (d)(2) and must be signed by all parties who have any interest in the property being valued based on its qualified use as of the date of the decedent’s death.

An interest in property is an interest that, as of the date of the decedent’s death, can be asserted under applicable law so as to affect the disposition of the specially valued property by the estate. Any person who at the decedent’s death has any such interest in the property, whether present, future, vested, or contingent, must enter into the agreement. Included are the following.

• Owners of remainder and executory interests;

• Holders of general or special powers of appointment;

• Beneficiaries of a gift over in default of exercise of any such power;

• Joint tenants and holders of similar undivided interests when the decedent held only a joint or undivided interest in the property or when only an undivided interest is specially valued; and

• Trustees of trusts and representatives of other entities holding title to or any interests in the property.

An heir who has the power under local law to challenge a will and thereby affect disposition of the property is not, however, considered to be a person with an interest in property under section 2032A solely by reason of that right. Likewise, creditors of an estate are not such persons solely by reason of their status as creditors.

If persons required to enter into the agreement desire that an agent act for them or cannot legally bind themselves due to infancy or other incompetency, or due to death before the election under section 2032A is timely exercised, a representative authorized by local law to bind persons in agreements of this nature may sign the agreement on the person’s behalf.

The IRS will contact the agent designated in the agreement 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. It is the duty of the agent as attorney-in-fact for the parties with interests in the specially valued property to furnish the IRS with any requested information and to notify the IRS of any disposition or cessation of qualified use of any part of the property.

If the skip person received interests in specially valued property that were shown on Schedule R-1 (Form 706), show these interests on the Schedule R (Form 706), Parts II and III worksheets, as appropriate. Do not use Schedule R-1 (Form 706) as a worksheet.

Completing the special-use value worksheets. On Schedule R (Form 706), Parts II and III, lines 3 through 5 and 7, enter -0-.

Completing the FMV worksheets.

• Schedule R (Form 706), Parts II and III, lines 3 and 4, fixed taxes and other charges. If valuing the interests at FMV (instead of special-use value) causes any of these taxes and charges to increase, enter the increased amount (only) on these lines and attach an explanation of the increase. Otherwise, enter -0-.

26 Instructions for Form 706 (Rev. 7-2026)