‘‘(C) such agreement provides that the his-
toric property will be open to the public for a
period of at least 20 years beginning on the
date on which the return of the tax imposed by
section 2001 is filed, and
‘‘(D) such agreement provides that any ad-
mission fees (if any) shall bear a reasonable re-
lationship to admission fees for other com-
parable tourist sites and shall be approved by
such State historic preservation agency (or
similar State agency).
The 20-year period referred to in subparagraph (C)
shall be suspended during reasonable periods of ren-
ovation.
‘‘(5) OPEN TO THE PUBLIC.—For the purposes
of paragraph (4)(C), a property shall be treated as
being open to the public for any year if a substantial
portion of the property is open for public visitation
for at least 8 hours per day and 6 days per week
during at least any 32 weeks of such year.
‘‘(6) TREATMENT
OF
QUALIFIED
HISTORIC
PROPERTY HELD BY A CORPORATION.—In the case
of a corporation all of the stock in which was held
on the date of the decedent’s death by the decedent
or members of the decedent’s family (as defined in
section 2032A(e)(2)), stock in such corporation shall
be treated for purposes of this section as qualified
historic property to the extent that the value of such
stock is attributable to qualified historic property
held by such corporation.
‘‘(c) TAX TREATMENT OF DISPOSITIONS AND FAIL-
URE TO COMPLY WITH AGREEMENT.—
‘‘(1) IMPOSITION
OF
ADDITIONAL
ESTATE
TAX.—If, during the 20-year period referred to in
subsection (b)(4)(C)—
‘‘(A) any person signing the written agree-
ment referred to in subsection (b)(4) disposes
of any interest in the qualified historic prop-
erty, or
‘‘(B) there is a violation of any provision
of such agreement (as determined under regula-
tions prescribed by the Secretary),
then there is hereby imposed an additional estate
tax.
‘‘(2) EXCEPTION WHERE TRANSFEREE AGREES
TO BE BOUND BY AGREEMENT.—No tax shall be im-
posed under paragraph (1) by reason of any disposi-
tion if the person acquiring the property agrees to
be bound by the agreement referred to in subsection
(b)(4) and to be liable for any tax under this sub-
section in the same manner as the person disposing
such property.
‘‘(3) AMOUNT
OF
ADDITIONAL
TAX.—The
amount of the additional tax imposed by paragraph
(1) with respect to any property shall be an amount
equal to—
‘‘(A) the excess of—
‘‘(i) what would (but for subsection
(a)) have been the tax imposed by section
2001 (reduced by the credits allowable),
over
‘‘(ii) the tax imposed by section 2001
(as so reduced), multiplied by
‘‘(B) the fraction—
‘‘(i) the numerator of which is the
number of months remaining after the
month in which the disposition or violation
occurs in the 20-year period referred to in
subsection (b)(4)(C), and
‘‘(ii) the denominator of which is 240.
‘‘(4) DUE DATE.—The additional tax imposed
by this subsection shall be due and payable on the
day which is 6 months after the date of the disposi-
tion or violation referred to in paragraph (1).
‘‘(5) LIABILITY FOR TAX.—Any person signing
the agreement referred to in subsection (b)(4) (other
than the executor) shall be personally liable for the
additional tax imposed by this subsection. If more
than 1 person is liable under this subsection, all
such persons shall be jointly and severally liable.
‘‘(6) CERTAIN OTHER RULES TO APPLY.—Rules
similar to the rules of sections 2013(f) and 2032A(f)
shall apply for purposes of this subsection.
‘‘(d) COORDINATION WITH DEDUCTION FOR TRANS-
FER OF EASEMENT.—Section 2055(f) shall not apply to
any interest referred to therein with respect to property
for which a deduction is allowed under subsection (a).’’
(b) TECHNICAL AMENDMENTS.—
(1) Subparagraph (A) of section 2056A(b)(10)
of such Code is amended by inserting ‘‘2057,’’ after
‘‘2056,’’.
(2) The table of sections for part IV of sub-
chapter A of chapter 11 of such Code is amended by
adding at the end the following new item:
‘‘Sec. 2057. Qualified historic property.’’
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply with respect to the estates of dece-
dents dying after the date of the enactment of this Act.
Æ