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Q: SECTION 1. EXCLUSION FROM ESTATE TAX FOR HISTORIC PROPERTY SUBJECT TO
PRESERVATION EASEMENT.

(a) In General.--Part IV of subchapter A of chapter 11 of the
Internal Revenue of 1986 (relating to taxable estate) is amended by
adding at the end the following new section:

''SEC. 2057. QUALIFIED HISTORIC PROPERTY.

''(a) General Rule.--For purposes of the tax imposed by section
2001, the value of the taxable estate shall be determined by deducting
from the value of the gross estate an amount equal to the value of any
qualified historic property included in the gross estate.
''(b) Qualified Historic Property.--
''(1) In general.--For purposes of this section, the term
'qualified historic property' means any historic property if--
''(A) on or before the date on which the return of
the tax imposed by section 2001 is filed, a qualified
real property interest described in section
170(h)(2)(C) in such property is held by a qualified
organization for the purpose described in section
170(h)(4)(A)(iv), and
''(B) such property is covered by an agreement
meeting the requirements of paragraph (4) which is
entered into on or before such date.
Such term includes personal property included within, or associated
with, qualified historic property (as defined in the preceding
sentence) if such personal property is covered by the agreement
referred to in subparagraph (B) which covers such qualified historic
property.
''(2) Historic property.--For purposes of paragraph (1),
the term 'historic property' means--
''(A) a certified historic structure (as defined in
section 170(h)(4)(B)), and
''(B) any other real property to the extent
reasonably necessary for public view and visitation of
such structure.
''(3) Qualified organization.--For the purposes of
paragraph (1), the term 'qualified organization' has the
meaning given to such term by section 170(h)(3).
''(4) Requirements for agreement.--For the purposes of
paragraph (1), an agreement meets the requirements of this
paragraph if--
''(A) such agreement is a written agreement signed
by each person in being who has an interest (whether or
not in possession) in the historic property (other than
the qualified organization),
''(B) such agreement is entered into with a State
historic preservation agency (or similar State agency)
and filed with the Secretary with the return of the tax
imposed by section 2001,
''(C) such agreement provides that the historic
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 admission
fees (if any) shall bear a reasonable relationship to
admission fees for other comparable 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 renovation.
''(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 Failure 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 agreement
referred to in subsection (b)(4) disposes of any
interest in the qualified historic property, or
''(B) there is a violation of any provision of such
agreement (as determined under regulations 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 imposed under paragraph (1) by
reason of any disposition 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 subsection 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 disposition 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 Transfer 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 subchapter 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 decedents dying after the date of
the enactment of this Act.
A:
Amends the Internal Revenue Code to provide that for purposes of determining estate tax the value of the taxable estate shall be determined by deducting from the value of the gross estate an amount equal to the value of any qualified historic property. Defines qualified historic property as any certified historic structure and any other real property necessary for public view and visitation that is held by a qualified charitable or governmental organization and is covered by an agreement which, among other things, provides that the historic property will be open to the public for a period of at least 20 years and has a reasonable admission fee.