Final determination
For purposes of paragraph (1), a value shall be treated as finally determined for purposes of chapter 12 if—
(A)#
the value is shown on a return under such chapter and such value is not contested by the Secretary before the expiration of the time referred to in paragraph (1) with respect to such return;
(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 taxpayer; or
(C)#
the value is determined by a court or pursuant to a settlement agreement with the Secretary.
For purposes of subparagraph (A), the value of an item shall be treated as shown on a return if the item is disclosed in the return, or in a statement attached to the return, in a manner adequate to apprise the Secretary of the nature of such item.