An estate was entitled to discount the value of its half undivided interest in artwork for the cost it would likely incur in a partition action to sell the art. This discount was based on an estimate of the cost to sell the paintings at auction. The court also indicated to factor into the valuation the volatility of the art market and its impact on the timing of a sale. R. Stone DC Cal. 2001-1 USTC Para. 60,540.
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