by the Secretary), the taxpayer attaches to the return for the taxable year in which such contribution is made a statement of value obtained from the Internal Revenue Service. In the case of a donor who dies before the date which is 20 years after the date of the initial fractional contribution, clause (iii)(II) is satisfied with respect to such initial fractional contribution if the donor's will specifies that all of the interests in such property will be contributed to the donee before such date. (B) Exceptions The Secretary may, by regulation, provide for exceptions to subparagraph (A)(i) in cases where all persons who hold an interest in the property make proportional contributions of an undivided portion of the entire interest held by such persons. Such regulations may modify the requirements of clauses (ii) and (iii) of subparagraph (A) to the extent necessary to carry out the purposes of this subparagraph. . (2) Valuation of subsequent gifts Paragraph (2) of section 170(o) of such Code is amended to read as follows: (2) Valuation of subsequent gifts In the case of any additional contribution, the fair market value of such contribution shall be determined by using a certified appraisal from the Art Advisory Panel of the Commissioner of Internal Revenue. . (3) Recapture of deduction Paragraph (3) of section 170(o) of such Code is amended— (A) by redesignating subparagraph (B) as subparagraph (C), and (B) by striking subparagraph (A) and inserting the following: (A) Recapture The Secretary shall provide for the recapture of the amount of any deduction allowed under this section (plus interest) with respect to any contribution of an undivided portion of a taxpayer's entire interest in tangible personal property— (i) in any case in which the donor fails to meet the requirements described in paragraph (1)(A)(iii), and (ii) in any case where such property is not in the physical possession of the donee (other than in the case of art which is fragile or unwieldy) and used in a use which is related to a purpose or