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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.

Stone v. U.S. (II)

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.

Parties Unable to Settle Discount for Fractional Interest in Artwork

Finding that the estate failed to carry its burden to prove support for 35% discount in fractional (50%) interest in art, the court confirms IRS 5% discount.

Do BV Methods Apply to Determining Discount for Fractional Interest in Art?

Court considers limits to business valuation “science” for determination of discounted value of fractional interest in art.

Stone v. United States

Finding that the estate failed to carry its burden to prove support for 35% discount in fractional (50%) interest in art, the Court confirms IRS 5% discount.

Stone v. U.S. (I)

Court considers limits to business valuation “science” for determination of discounted value of fractional interest in art.

Janis v Commissioner

Sidney Janis owned and operated a well-known art gallery in New York City. In 1988, he transferred ownership of the gallery to a trust, naming himself and his sons, Conrad and Carroll, trustees. Sidney Janis died a year later, leaving Conrad and Carroll ...

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