In the case of any interest in qualified real property (within the meaning of ), an amount equal to the adjusted tax difference attributable to such interest (within the meaning of ) shall be a lien in favor of the United States on the property in which such interest exists.
(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 with respect to such interest.
(1) In general
The rule set forth in paragraphs (1), (3), and (4) of 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” includes qualified replacement property (within the meaning of ) and qualified exchange property (within the meaning of ).
To the extent provided in regulations prescribed by the Secretary, the furnishing of security may be substituted for the lien imposed by this section.