Summary
Ninth Circuit rejects estate’s appeal of 5% discount for a 50% undivided fractional interest in art collection, based on insufficient appraisal evidence to carry the taxpayer’s burden of proof to show that IRS assessment was wrong.
Stone v. U.S. (II)
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See Also
9th Circuit Follows Up on Value of Fractional Interest in Major Art Collection
9th Circuit rejects estate’s appeal of 5% discount for a 50% undivided fractional interest in art collection, based on insufficient appraisal evidence to carry the taxpayer’s burden of proof to show that IRS assessment was wrong.