This analysis used simulation to compare the cost of intergenerational transfer of farm estates under the pre-1981 tax rules and the Economic Recovery Tax Act of 1981 (ERTA) provisions. ERTA reduces transfer costs for almost all the estates considered. Large estates tend to benefit more than small estates if they qualify for use valuation or if they are large enough to be affected by the reduction in tax rates. ERTA does not create new forces for change in U.S. agriculture, but it tends to strengthen the tendency toward larger farm size and favor those who already own farm resources.