text: 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) Definitions.--For purposes of this section--
              ``(1) Qualified historic property.--
                      ``(A) In general.--The term `qualified historic 
                  property' means any historic property if--
                              ``(i) 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
                              ``(ii) such property is covered by an 
                          agreement meeting the requirements of 
                          subsection (c) which is entered into on or 
                          before such date.
                      ``(B) Treatment of personal property.--Such term 
                  includes personal property included within, or 
                  associated with, qualified historic property (as 
                  defined in paragraph (1)) if such personal property--
                              ``(i) is held by the decedent holding such 
                          qualified historic property,
                              ``(ii) has been so included within, or 
                          associated with, such qualified historic 
                          property throughout the 10-year period ending 
                          on the date of the decedent's death, and
                              ``(iii) is covered by the agreement 
                          referred to in subparagraph (A)(ii) which 
                          covers such qualified historic property.
              ``(2) Historic property.--The term `historic property' 
          means--
                      ``(A) any building (and its structural 
                  components)--
                              ``(i) which is designated as a National 
                          Historic Landmark under section 101 of the 
                          National Historic Preservation Act throughout 
                          the 10-year period ending on the date of the 
                          decedent's death,
                              ``(ii) which was owned by the decedent or a 
                          member of the decedent's family (as defined in 
                          section 2032A(e)(2)) throughout such 10-year 
                          period, and
                              ``(iii) which was originally used for 
                          residential purposes, and
                      ``(B) any other real property to the extent 
                  reasonably necessary for public view and visitation of 
                  the property described in subparagraph (A).
              ``(3) Qualified organization.--The term `qualified 
          organization' has the meaning given to such term by section 
          170(h)(3).
              ``(4) 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))--
                      ``(A) 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, but
                      ``(B) the requirements of subsection (c) shall be 
                  met only if each member of the decedent's family 
                  holding such stock on such date sign the agreement 
                  referred to in subsection (c).
      ``(c) Requirements for Agreement.--
              ``(1) In general.--For purposes of subsection 
          (b)(1)(A)(ii), an agreement meets the requirements of this 
          subsection 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 only 
                  activities carried on at the historic property are 
                  activities which are substantially related (aside from 
                  the need for income or funds or the use made of the 
                  profits derived) to--
                              ``(i) the public view and visitation of 
                          such property and the property described in the 
                          last sentence of subsection (b)(1) with respect 
                          to such property), and
                              ``(ii) the maintenance and preservation of 
                          such property and surrounding areas for such 
                          public view and visitation,
                      ``(D) 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
                      ``(E) 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).
              ``(2) Treatment of food, lodging, and meeting facilities 
          provided to general public.--The regular carrying on--
                      ``(A) a trade or business of providing lodging 
                  shall be treated as not substantially related for 
                  purposes of paragraph (1)(C),
                      ``(B) a trade or business of providing food shall 
                  be treated as not substantially related for purposes of 
                  paragraph (1)(C) unless--
                              ``(i) such food is only provided to 
                          individuals who pay the generally applicable 
                          admission fees (if any) for admission to the 
                          property by individuals to whom no food is 
                          provided, and
                              ``(ii) only an insubstantial portion of the 
                          structures on the historic property is devoted 
                          to the provision of such food, and
                      ``(C) a trade or business of providing facilities 
                  for meetings or events shall be treated as not 
                  substantially related for purposes of paragraph (1)(C) 
                  unless all of the net proceeds from such trade or 
                  business are used for maintenance or preservation of 
                  the historic property.
              ``(3) Open to the public.--For the purposes of paragraph 
          (1)(D), the 20-year period referred to in such paragraph shall 
          be suspended during reasonable periods of renovation.
      ``(d) 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 (c)(1)(D)--
                      ``(A) any person signing the written agreement 
                  referred to in subsection (c) 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 for certain transferees who agree to be 
          bound by agreement.--No tax shall be imposed under paragraph 
          (1) by reason of any disposition if the person acquiring the 
          property--
                      ``(A) is a qualified organization or is a member of 
                  the family (as defined in section 2032A(e)(2)) of the 
                  person disposing of such property, and
                      ``(B) 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 of such property.
              ``(3) Amount of additional tax.--
                      ``(A) In general.--The amount of the additional tax 
                  imposed by paragraph (1) with respect to any property 
                  shall be an amount equal to the applicable percentage 
                  of 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).
                      ``(B) Applicable percentage.--For purposes of 
                  subparagraph (A), the applicable percentage is the 
                  percentage determined in accordance with the following 
                  table for the year (of 20-year period referred to in 
                  subsection (c)(1)(D)) in which the event described in 
                  paragraph (1) occurs:
  
                  ``If the event
                                                           The applicable
                  occurs during:
                                                           percentage is:
                  The 1st 12 years of such 20-year       100 percent     
                      period.
                  The 13th or 14th year of such period.   80 percent     
                  The 15th or 16th year of such period.   60 percent     
                  The 17th or 18th year of such period.   40 percent     
                  The 19th or 20th year of such period.   20 percent.    
              ``(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 (c) (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 1016(c), 2013(f), and 2032A(f) shall apply 
          for purposes of this subsection.
      ``(e) Other Special Rules.--
              ``(1) 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).
              ``(2) Denial of deduction of indebtedness on excluded 
          property.--No deduction shall be allowed under section 2053 for 
          indebtedness in respect of property the value of which is 
          deducted under subsection (a).
              ``(3) Submission of annual inventories of personal 
          property.--The Secretary shall require the submission to the 
          Secretary of such inventories of personal property which is 
          qualified historic property as the Secretary determines are 
          necessary for purposes of this section.''
      (b) Technical Amendments.--
              (1) Subsection (a) of section 1014 of such Code is amended 
          by striking the period at the end of paragraph (3) and 
          inserting ``, or'' and by adding after paragraph (3) the 
          following new paragraph:
              ``(4) in the case of property the value of which was 
          deducted under section 2057(a), the adjusted basis of such 
          property in the hands of the decedent immediately before the 
          death of the decedent.''
              (2) Subparagraph (A) of section 2056A(b)(10) of such Code 
          is amended by inserting ``2057,'' after ``2056,''.
              (3) 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.
target: 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.  Requires, among other things, that the historic property will be open to the public for a period of at least 20 years and will have reasonable admission fees.
feat_title: A bill to amend the Internal Revenue Code of 1986 to provide that the value of qualified historic property shall not be included in determining the taxable estate of a decedent.