before the expiration of the time for assessing a tax under chapter 12, (B) in a case not described in subparagraph (A), the value is specified by the Secretary and such value is not timely contested by the donor of such property, or (C) the value is determined by a court or pursuant to a settlement agreement with the Secretary. (3) Regulations The Secretary may by regulations provide exceptions to the application of this subsection. . (b) Information reporting (1) In general Section 6035 of the Internal Revenue Code of 1986 is amended— (A) in the heading, by inserting or by gift after decedent