(proposed transfer of farmland by non-corporate family farming operation held in trust for qualified heir to an LLC is eligible for special use valuation election under I.R.C. Sec. 2032A; later lease of elected land by LLC to partnership will not trigger recapture under I.R.C. Sec. 2032A(c)(1)(B); partnership's sole right to decide to pay either fixed cash rent or rent based on percentage of crops grown substantially similar to facts of Estate of Gavin v. Comr., 113 F.3d 802 (8th Cir. 1997) where court ruled that qualified heir's option to pay cash rent or crop share resulted in the qualified heirs being at production risk on their return from their land ownership; IRS points out that such leases are not disqualified per se as cash leases and reminds readers on page eight of the rulings that post-death leases must be "substantially dependent on production"; IRS, in no way, leaves impression in rulings that straightforward post-death cash leasing is permissible; in addition, while not mentioned in rulings, facts of rulings not within scope of I.R.C. 2032A(c)(7)(E) which specifies that rental of elected land on "net cash basis" by a lineal descendant of the decedent to a member of the family of the lineal descendant not a recapture triggering event because some lessees, while family members, not technically "members of the family" under I.R.C. Sec. 2032A and, therefore, not lineal descendant of decedent; result of rulings is very favorable to the spirit of the law and the intent of the Congress, but where IRS could, technically, disqualify the estate from I.R.C. Sec. 2032A).