On March 11, 2013, the U.S. Tax Court issued its highly anticipated opinion in Estate of Elkins v. Commissioner,1 in which the court concluded, among other things, that there was no bar, as a matter of law, to claiming a pro rata discount on a decedent’s undivided fractional interests in 64 works of art. The Elkins decision followed on the heels of Robert G. Stone v. United States,2 which was the first case to consider whether valuation discounts should be allowed for undivided ...

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