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(A) In general.--In the case of any qualified woodland
with respect to which the executor elects to have this
subparagraph apply, trees growing on such woodland shall not
be treated as a crop.
(B) Qualified woodland.--The term "qualified woodland"
means any real property which–-
(i) is used in timber operations, and
(ii) is an identifiable area of land such as an
acre or other area for which records are normally
maintained in conducting timber operations.
(C) Timber operations.--The term "timber operations"
means--
(i) the planting, cultivating, caring for, or
cutting of trees, or
(ii) the preparation (other than milling) of trees
for market.
(D) Election.--An election under subparagraph (A)
shall be made on the return of the tax imposed by section
2001. Such election shall be made in such manner as the
Secretary shall by regulations prescribe. Such an election,
once made, shall be irrevocable.
The report of the Senate Finance Committee accompanying the
1981 enactment of section 2032A(e)(13) specifically states that
an election under section 2032A(e)(13) results in the standing
timber’s being thereafter specially valued as "part of the
qualified real property on which the timber is located, rather
than valuing it as other growing crops." S. Rept. 97-144, at 135
(1981), 1981-2 C.B. 412, 465. The Senate Finance Committee
report explains how this provision interacts with the rent
capitalization method:
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