into account soil capacity, terrain configuration,
and similar factors.
‘‘(D) Any other factor which fairly values
the timber value of the property.
‘‘(6) APPLICABLE DEFINITIONS AND RULES OF
SECTION 2032A.—
‘‘(A) DEFINITIONS.—Except as otherwise
provided in this section, any term used in this
section which is also used in section 2032A
shall have the meaning given such term by sec-
tion 2032A.
‘‘(B) RULES.—Rules similar to the rules of
the following provisions of section 2032A shall
apply to this section, by substituting ‘qualified
forestland’ for ‘qualified real property’ and
‘qualified forest use’ for ‘qualified use’, and
shall apply to qualified devisees as well as quali-
fied heirs:
‘‘(i) Paragraphs (2)(D), (4), (5), and
(7)(A) (by substituting ‘25 years’ for ‘10
years’) of subsection (c).
‘‘(ii) Subsection (d)(3).
‘‘(iii) Paragraphs (9), (10), (11), and
(14) (by substituting ‘active management’
for ‘material participation’) of subsection
(e).
‘‘(iv) Subsections (f) and (g).
‘‘(f) SPECIAL RULES FOR INVOLUNTARY CONVER-
SIONS OF QUALIFIED FORESTLAND.—
‘‘(1) TREATMENT OF CONVERTED PROPERTY.—
‘‘(A) IN GENERAL.—If there is an involun-
tary conversion of an interest in qualified
forestland—
‘‘(i) no tax shall be imposed by sub-
section (c) on such conversion if the cost of
the qualified replacement property equals
or exceeds the amount realized on such
conversion; or
‘‘(ii) if clause (i) does not apply, the
amount of the tax imposed by subsection
(c) on such conversion shall be the amount
determined under subparagraph (B).
‘‘(B) AMOUNT OF TAX WHERE THERE IS
NOT COMPLETE REINVESTMENT.—The amount
determined under this subparagraph with re-
spect to any involuntary conversion is the
amount of tax which (but for this subsection)
would have been imposed on such conversion re-
duced by an amount which—
‘‘(i) bears the same ratio to such tax,
as
‘‘(ii) the cost of the qualified replace-
ment property bears to the amount real-
ized on the conversion.
‘‘(2) TREATMENT
OF
REPLACEMENT
PROP-
ERTY.—For purposes of subsection (c)—
‘‘(A) any qualified replacement property
shall be treated in the same manner as if it
were a portion of the interest in qualified
forestland which was involuntarily converted;
except that with respect to such qualified re-
placement property the 25-year period under
paragraph (1) of subsection (c) shall be ex-
tended by any period, beyond the 2-year period
referred to in section 1033(a)(2)(B)(i), during
which the qualified devisee or qualified heir was
allowed to replace the qualified forestland;
‘‘(B) any tax imposed by subsection (c) on
the involuntary conversion shall be treated as a
tax imposed on a partial disposition, and
‘‘(C) subparagraph (A)(ii) of subsection
(c)(1) shall be applied by not taking into ac-
count periods after the involuntary conversion
and before the acquisition of the qualified re-
placement property.
‘‘(3) DEFINITIONS AND SPECIAL RULES.—For
purposes of this subsection—
‘‘(A) 
INVOLUNTARY
CONVERSION.—The
term ‘involuntary conversion’ means a compul-
sory or involuntary conversion within the mean-
ing of section 1033.
‘‘(B) QUALIFIED
REPLACEMENT
PROP-
ERTY.—The term ‘qualified replacement prop-
erty’ means—
‘‘(i) in the case of an involuntary con-
version described in section 1033(a)(1),
any real property into which the qualified
forestland is converted, or
‘‘(ii) in the case of an involuntary con-
version described in section 1033(a)(2),
any real property purchased by the quali-
fied devisee or qualified heir during the pe-
riod specified in section 1033(a)(2)(B) for
purposes 
of 
replacing 
the 
qualified
forestland.
Such term only includes property which is to be
used for the qualified forest use set forth in