Stone v. U.S. (filed 5/25/07 - fractional interest in artwork)

This U.S. District Court case held that no fractional interest discount was applicable to artwork as the taxpayers’ expert did not find any data regarding sales of undivided interests in art and the IRS’ experts testified that while they were aware of sales of undivided interests in art occurring, none of these had ever occurred at a discount. However, a discount for the costs to partition was allowed.


Note: For full-text of this case, this article can be found at the website of the University of California, Irvine.