Valuing Fractional Interests in Art for Estate Tax Purposes

4 Pages Posted: 31 May 2013

See all articles by Wendy C. Gerzog

Wendy C. Gerzog

University of Baltimore - School of Law

Date Written: May 30, 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.

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, H29

Suggested Citation

Gerzog, Wendy C., Valuing Fractional Interests in Art for Estate Tax Purposes (May 30, 2013). Tax Notes, Vol. 139, No. 9, 2013. Available at SSRN:

Wendy C. Gerzog (Contact Author)

University of Baltimore - School of Law ( email )

1420 N. Charles Street
Baltimore, MD 21218
United States
410-837-4522 (Phone)

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