The URL can be used to link to this page

Home My WebLink About03-1338W U.S. GOVERNMENT PRINTING OFFICE 1988-224-843 Form 668-H (Rev. July 1987) Department of the Treasury -- Internal Revenue Service '7/.o, 0 3~ Notice of Federal Estate Tax Lien Under Internal Revenue Laws District Ph~ 1 ~d~]~hi;a Serial Number For Optional Use by Recording Ofhce ~ '-//I Notice is given under the provisions of section 6324B of the Internal Revenue Code that a lien exists in favor of the United States against the specific property des- cribed below for additional Federal estate tax imposed by section 2032A(c) due to the special valuation elected under section 2032A. Name of Estate Name and address of agent designated bythequalified heirs fordealing with IRS mgardingthespeciallyvaluedpropedy. Steven G. Gowman 2999 Dickinson Avenue Camp Hill, PA 17011 MayDate°fDeathl, 2001 IDecedent'ss°cialsecurityNumber187-16-6525 DescriptionofPro~rtytoWhichLienAttaches 3 Long Lane Silver Spring Township, Cumberland County Mechanicsburg, PA 17055 Amount of Additional Tax $82,O69.OO F-- 7'L Pi~ce of Filing Prothonotary Office Cumberland County Courthouse Carlisle, PA 17013 This notice was prepared and signed at RCJO Arr, h St =: Roo_m. 3259; Phi!a_; PA 19105 , on this the~13th .day of March Sig natu re ,/,~~ Carlo Gonnel 2003 ITitle Revenue Officer/Advisor Part I · To be kept by recording office Form 668-H (Rev. 7-87) C Z Internal Revenue Code Sec. 6324B. Special lien for additional estata tax attributable to tarm, etc., valuation. (a) General rule. In the case of any interest in qualified real property (within the meaning of section 2032A(b}), an amount equal to the adjusted tax difference attributable to such ~nterest (within the meaning of section 2032A(c)(2)(B)) shall be a lien in favor of the United States on the property in which such interest exists. (b) Period of lien. The lien imposed by this section shall arise at the time ' an election is filed under section 2032A and shall continue with respect to any interest in the qual;fied real property-- (1) until the liability for tax under subsection (c) of section 2032A with respect to such interest has been satisfied or has become unenforceable by reason of lapse of time, or (2) until it is established to the satisfaction of the Secretary that no further tax liability may arise under section 2032A(c) with respect to such interest, (C) Certain Rules and Definitions Made Appli- cable. (1) In general. The rule set forth in paragraphs (1), (3), and (4) of section 6324A(d) shall apply with respect to the lien imposed by this section as if it were a lien imposed by section 6324A (2) Qualified real property. For purposes of this section, the term "qualified real property" in- cludes qualified replacement property (within the meaning of section 2032A(h)(3)(B)) and qualified exchange property (within the meaning of section 2032A(i) (3)). (d) Substitution of security for lien. To the extent provided in regulations prescribed by the Secretary, the furnishing of security may be substituted for the lien imposed by this section. Sec. 6324A. Special lien for estate tax deferred under section 6166. (d) Special rules. (1) Requirement that lien be tiled. The lien imposed by this section shall not be valid as against any purchaser, holder of a security interest, mechan- ic's lien, or judgement lien creditor until notice thereof which meets the requirements of section 6323(f) has been filed by the Secretary Such notice shall not be required to be refiled (2) PeriOd of lien. The lien imposed by this section shall arise at the time the executor is discharged from liability under section 2204 (or. if earlier, at the time notice ~s filed pursuant to paragraph (1)) and shall continue until the liablity for the deferred amount is satisfied or becomes unenforceable by reason of lapse of tlnqe (3) Priorities. Even though notice of a lien imposed by this section has been filed as provided in para- graph (1) such lien shall not be valid- (A) Real property tax and special assessment liens. To the extent provided in section. 6323(b)(6). (B) Real property subject to a mechanic's lien for repairs and improvements. In the case of any real property subject to a lien for repair or improvement, as against a mechanic's lienor (C) Real property construction or improvement financing agreement. As against any security interest set forth in paragraph (3) of section 6323(c) (whether such security interest came into existence before or after tax lien filing). Subparagraphs (B} and (C) shall not apply to any security interest which came into existence after the date on which the Secretary filed notice (in a manner similar to notice filed under section 6323(f)) that payment of the deferred amount has been accelerated under section 61Co6(g). (4) Lien lo be in lieu of Section 6324 lien; If there is a lien under this sectioh On. any property with respect to any estate, there shall not be any lien under section 6324 on such property with respect t~ the same estate Sec. 6323. Validity and priority against certain persons, (b) Protection for certain intaresta even Ihough notice filed. Even though notice of a lien imposed by section 6321 has been filed, such lien shall not be valid-- (6) Real property tax and special assessment i~ne, With respect to real property, as against a holder of a lien upon such property, if such lien is entitled under local law to priority over security inter- ests in such property which are prior in time, and such lien secures payment of- (A) A tax of general application levied by any taxing authority based upon the value of such property; (B) A special assessment imposed directly upon such property by any taxing authority, if such assessment is imposed for the purpose of defray- ing the cost of any public improvement: or (C) charges for utilities or public services fur- nished to such property by the United States, a State or political subdivision thereof, or an instrumentality of any one or more of the foregomg. (C) Protection for certain commercial transactions financing agreements, etc.-- (3) Real properly construction or improve- mart lln~lncing agreement. For the purposes of this subsection- (A) Defintion The term ~'real property construc- tion or improvement financing agreement" means an agreement to make cash disburse- ments to finance- (i) the construction or improvement of real property, (ii) a contract to construct or improve real property, or (iii) the raising or harvesting of a farm crop or the raising of livestock or other animals For the purposes of clause (iii), the furnishing of goods and services shall be treated as the dis- bursement of cash (B) Limitation on qualified property. The term. "qualified property," when used with respect to a - rea[ property construction or impro~'ement finan- cing agreement, includes only (i) in the case of subparagraph (A)(i), the real property with respect to which thee Cor~struc- lion or improvement has been or is to be made, (ii) in the case of .subparagraph (A)(ii), the proceeds of the contract described therein, and (iii) in the case of subparagraph (A)(iii), prop- erty sublect'to the lien imposed by section 6321 at the time of tax lien filing and the crop or the livestock or other animals referred tO in subparagraph (A) (iii). (f) Place for filing notice; form. (1) INace for filing. The notice referred to in Sub- section (a) shall be filed- (A) Under stale'laws. (i) Real property lB ,the case of real prop- arty, in one office withih the State (or the county~ or other governmental subdivision), as designated by the laws of such State1 in which the property subject to the lien is siluated; and (ii) Personal property. In the case of personal property, whether tangible Or intangible, in one office within the State (or county, or ott'~er governmental subdivision), as designated by the laws of such State, in which the property subject to the lien is situated; or (B) With clerk of district court In the office of the clerk of the United States district court for the judicial district in which the property subject to the lien is situated, whenever the State has not by law designated one office which meets the requirements of subparagraph (A); or (C) With recorder of deeds of the District of Columbia. In the office of the Recorder of Deeds of the District of Columbia, if the property sub- iect to the lien is situated in the District of Columbia (2) Situs of properly subject !0 lien. For purposes of paragraphs (1) and (4), property shall be deemed be situated-- (A) Real propertyl In the case of real P!~operty, at its physical location; or (B) Personal property In the CGse of personal property;, whet~er tangible or intangible, at the residence of the taxpayer at the time the notice of lien is filed. For purposes of paragraph (2)(B}, the residence of a corporation or partnershi,r~ shall be deemed to be the place at which the principal executive office of the business is located, and the residence of a taxpayer whose residence i~ without the United States shall be deemed to be in the District of Columbia (3} Form. The form and content ol the notice referred to in subssction (a) shall be prescribed by the Secrs~ary. Such notice shall be valid notwithstanding any other provision of law regarding the form or conteht of a notice of lien. Form 668-H (Rev. July 1987) Department of the Treasury-- Interr. Revenue Service Certificate of Release of Federal Estate Tax Lien District tSerial Number I certify that the requirements of section 6325(a) of the Internal Revenue Code have been satisfied for the tax liability (including all statutory additions) shown below on the following-named estate, and that the lien for the tax and statutory additions has been released. The proper officer in the office where notice of internal revenue March 27th t 1~' :200~,~ is authorized to note in the tax was filed on books the release of this lien, as far as it relates to the following. Name of Estate Name and address of agent designated by the qualified huirs for dealing with IRS regarding the specially valued property. Date of Death ~" Decedent's Social Security Number 187-1=~=6525 .'y. 1, ;M~I : Description of Property to Which Lien Attaches ~h~c~~ P~ 17055 ,/ For Optional Use by Recording Off;ce ~03-1338 Amount of Additional Tax S 82,069.00 Place of Filing Prothonot&~Y O~ice CumberlnndCountY Couz~bouse Carlisle, PA 17013 This certificate was prepared and signed _, on this Signature off~ic~ Form 668-H (Rev. 7-87) Part 3 - To be kept by recording office