for farming purposes The use of such property will be as a farm for farming purposes at all times during the recapture period. (2) Recapture agreement The transferee has been notified of the recapture liability arising from a disposition or change in the use of such property at any time during the recapture period. (d) Treatment of disposition or change in use of property (1) In general If there is a recapture event during the recapture period with respect to any qualified farm property, then the tax imposed under this chapter on the transferee referred to in subsection (a) for the taxable year which includes the first such recapture event shall be increased by the amount excluded from the product of— (A) the transferor’s gross income under subsection (a) with respect to such qualified farm property, multiplied by (B) the rate of tax in effect under section (1)(h)(1)(D). (2) Recapture event defined For purposes of this subsection, the term recapture event means, with respect to any qualified farm property— (A) Cessation of operation The cessation of the operation of such property as a farm for farming purposes at any time in the recapture period. (B) Failure to materially participate The failure of a qualified farmer to materially participate in the operation of the farm at any time during the recapture period. (C) Change in ownership (i) In general Except as provided in clause (ii), the disposition of any interest in such property by the transferee referred to in subsection (a) during the recapture period. (ii) Agreement to assume recapture liability Clause (i) shall not apply to any farm property if the person acquiring the interest referred to in such clause agrees in writing to assume the recapture liability of the person disposing of such interest. In the event of such an assumption, this subsection shall apply to the person acquiring such interest as though such person were the transferee referred to therein (and this subsection shall be applied as if there had been no change in ownership). (3) Special