Valuing Fractional Interests in Art for Estate Tax Purposes
Wendy C. Gerzog
University of Baltimore - School of Law
May 30, 2013
Tax Notes, Vol. 139, No. 9, 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 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 section 2703 and then the court determined the value of decedent’s interests in the art.
Number of Pages in PDF File: 4
Keywords: valuation, estate tax, fractional interests, fractional interests in art, LLC, section 2703, restricted agreements, discounts, Elkins
JEL Classification: K11, K34, H2, H10, H20, H22, H23, H24, H29Accepted Paper Series
Date posted: May 31, 2013
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