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Case Summary

Estate of Elkins v. Commissioner

Estate of James A. Elkins v. Commissioner of Internal Revenue, 140 T.C. 86 (2013); aff’d in part and rev’d in part, 767 F.3d 443 (5th Cir. 2014).

Précis

This complex federal tax case examined whether or not a fractional ownership discount was applicable to a 73% undivided interest in sixty-four pieces of fine art, and how that impacted the fair market value of a decedent’s estate. After the IRS flagged a multi-million dollar deficiency in the estate tax…






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