Friday, May 31, 2013
Wendy C. Gerzog (Baltimore), Valuing Fractional Interests in Art for Estate Tax Purposes, 139 Tax Notes 1073 (May 27, 2013):
It is difficult to value fractional interests in art because there is virtually no market in those interests. Nevertheless, the Tax Court in Estate of Elkins [140 T.C. No. 5 (2013)] valued the decedent’s fractional interests in multiple artworks, which the decedent and his children highly cherished. First, the court addressed the restricted agreements under § 2703 and then the court determined the value of decedent’s interests in the art.
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