‘‘(I) is a qualified organization 
(as defined in paragraph (3)) with a 
purpose of environmental protection, 
land conservation, open space preser-
vation, or historic preservation, and 
‘‘(II) has the resources to man-
age and enforce the restriction and a 
commitment to do so, and 
‘‘(iii) in the case of any contribution 
made in a taxable year beginning after the 
date of the enactment of this subpara-
graph, the taxpayer includes with the tax-
payer’s return for the taxable year of the 
contribution— 
‘‘(I) a qualified appraisal (within 
the meaning of subsection (f)(11)(E)) 
of the qualified property interest, 
‘‘(II) photographs of the entire 
exterior of the building, and 
‘‘(III) a description of all restric-
tions on the development of the build-
ing.’’. 
(b) FILING FEE FOR CERTAIN CONTRIBUTIONS.— 
Subsection (f) of section 170 of such Code (relating to 
disallowance of deduction in certain cases and special
rules) is amended by inserting at the end the following 
new paragraph: 
‘‘(13) CONTRIBUTIONS OF CERTAIN INTERESTS 
IN BUILDINGS LOCATED IN REGISTERED HISTORIC 
DISTRICTS.— 
‘‘(A) IN GENERAL.—No deduction shall be 
allowed with respect to any contribution de-
scribed in subparagraph (B) unless the tax-
payer includes with the return for the taxable 
year of the contribution a $500 filing fee. 
‘‘(B) CONTRIBUTION DESCRIBED.—A con-
tribution is described in this subparagraph if 
such contribution is a qualified conservation 
contribution (as defined in subsection (h)) 
which is a restriction with respect to the exte-
rior of a building described in subsection 
(h)(4)(C)(ii) and for which a deduction is 
claimed in excess of the greater of— 
‘‘(i) 3 percent of the fair market value 
of the building (determined immediately 
before such contribution), or 
‘‘(ii) $10,000. 
‘‘(C) DEDICATION OF FEE.—Any fee col-
lected under this paragraph shall be used for
the enforcement of the provisions of subsection 
(h).’’. 
(c) EFFECTIVE DATE.— 
(1) SPECIAL RULES FOR BUILDINGS IN REG-
ISTERED
HISTORIC
DISTRICTS.—The amendments 
made by subsection (a) shall apply to contributions 
made after the date of the enactment of this Act. 
(2) FILING
FEE.—The amendment made by 
subsection (b) shall apply to contributions made 180 
days after the date of the enactment of this Act. 
SEC. 2. PROVISIONS RELATING TO SUBSTANTIAL AND 
GROSS OVERSTATEMENTS OF VALUATIONS 
OF CHARITABLE DEDUCTION PROPERTY. 
(a) SUBSTANTIAL AND GROSS OVERSTATEMENTS OF 
VALUATIONS OF CHARITABLE DEDUCTION PROPERTY.— 
(1) IN GENERAL.—Section 6662 of the Internal 
Revenue Code of 1986 (relating to imposition of ac-
curacy-related penalties) is amended by adding at 
the end the following new subsection: 
‘‘(i) SPECIAL RULES FOR CHARITABLE DEDUCTION 
PROPERTY.—In the case of charitable deduction property 
(as defined in section 6664(c)(3)(A))— 
‘‘(1) 
the 
determination 
under 
subsection 
(e)(1)(A) as to whether there is a substantial valu-
ation misstatement under chapter 1 with respect to
the value of the property shall be made by sub-
stituting ‘150 percent’ for ‘200 percent’, and 
‘‘(2) 
the 
determination 
under 
subsection 
(h)(2)(A)(i) as to whether there is a gross valuation 
misstatement with respect to the value of the prop-
erty shall be made by substituting ‘200 percent’ for 
‘400 percent’ and by substituting ‘150 percent’ for 
‘200 percent’ in applying subsection (e)(1)(A) for 
purposes of such determination.’’. 
(2) ELIMINATION OF REASONABLE CAUSE EX-
CEPTION
FOR
GROSS
MISSTATEMENTS.—Section 
6664(c)(2) of such Code (relating to reasonable 
cause exception for underpayments) is amended by 
striking ‘‘paragraph (1) shall not apply unless’’ and 
inserting ‘‘paragraph (1) shall not apply. The pre-
ceding sentence shall not apply to a substantial valu-
ation overstatement under chapter 1 if’’. 
(b) QUALIFIED APPRAISERS AND APPRAISALS.— 
(1) IN GENERAL.—Subparagraph (E) of section 
170(f)(11) of such Code is amended to read as fol-
lows: 
‘‘(E) QUALIFIED
APPRAISAL
AND
AP-
PRAISER.—For purposes of this paragraph— 
‘‘(i) 
QUALIFIED
APPRAISAL.—The 
term ‘qualified appraisal’ means, with re-