United States Second Circuit

Judgment of the tax court assessing income tax deficiencies related to sales of inherited works of art, is affirmed as the fair market value of the artwork upon which the estate tax was calculated also constitutes the cost basis of the property for income tax purposes when it was later sold.

Appellate Information

• Decided 11/15/2006
• Published 11/16/2006

Judges

• KORMAN, District Judge., Before POOLER, SOTOMAYOR, Circuit Judges, and KORMAN, District Judge.

Court

• United States Second Circuit

Counsel

• For Appellant:
  
• Brandon White, Foley Hoag, LLP, Boston, MA, for Petitioners-Appellants (John H. Henn, attorney, on the brief).


• For Appellees:
  
• Francesca U. Tamami, Attorney, Department of Justice, Tax Division, Washington, D.C., for Respondent-Appellee (Eileen O'Connor, Assistant Attorney General, Jonathan S. Cohen, attorneys, on the brief).