Selected Issues Involving Art and Other Collectibles A Presentation to The Dallas Bar Association Probate, Trusts & Estates Section November 26, 2013

Presented By

Norman A. Lofgren, Esq. Looper, Reed & McGraw, P.C. 1601 Elm Street, Suite 4600 Dallas, TX 75201 Mark Prendergast Heritage Auctions 5850 San Felipe, Suite 500 Houston, Texas 77057 Karl Chiao, Esq. Heritage Auctions 3500 Maple Avenue, 17th Floor Dallas, Texas 75219

795925.1

Selected Tax Involving Art and Other Collectibles

A.

INTRODUCTION 1.

Art and Collectibles

The Internal Revenue Service defines “art” as including “paintings, sculptures, watercolors, prints, drawings, ceramics, antiques, decorative arts, textiles, carpets, silver, rare manuscripts, historical memorabilia, and other similar objects.” Form 8283 It defines “collectibles” as including coins, stamps, books, gems, jewelry, sports memorabilia, dolls, etc.” Form 8283. The term collectible is defined in IRC §§ 1(h)(5) and 408(m)(2) as meaning: a. b. c. d. e. f. 2.

any work of art, any rug or antique, any metal or gem, any stamp or coin, any alcoholic beverage or any other tangible personal property specified by the Secretary.

Situations Involving Dispositions of Art and Collectibles

Dispositions of art and collectibles occur for a number of reasons; but, dispositions generally fall within the following broad categories: a.

Death of Owner

b.

Gifts by Owner

c.

Sales and Exchanges by Owner

d.

Charitable Donations

e.

Casualty Losses

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B.

TAX IMPLICATIONS AND RULES 1.

Income Taxation a.

Sales i.

Capital Asset

Internal Revenue Code (“IRC”) § 1221(a) defines capital assets as “property held by a taxpayer (whether or not connected with his trade or business).” However, IRC § 1221(a)(1) expressly excludes from the definition of capital assets inventory and IRC § 1221(a)(3) expressly excludes: “a copyright, a literary, musical or artistic composition, a letter or memorandum, or similar property, held by (A)

a taxpayer whose personal efforts created such property,

(B) in the case of a letter, memorandum, or similar property, a taxpayer for whom such property was prepared or produced, or (C) a taxpayer in whose hands the basis of such property is determined … in whole or part by reference to the basis of such property in the hands of a taxpayer described in subparagraph (A) of (B).” The Treasury Regulations (Treas. Reg. § 1.1221-1(c)) fail to provide examples of the kind of property that would constitute a copyright or a literary, musical, or artistic composition. But, it is clear from the language of the statute that the creator of the work, and the person for whom a “letter, memorandum or similar property” was created and anyone who acquires the property from either of the foregoing in a tax-free transaction will not be able to qualify the property as a capital asset.

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ii.

Special Capital Gain Rate / Definition of Collectibles -

IRC § 1(h)(4) specifies a 28% tax rate on “collectibles gain.” The term collectible is defined in IRC §§ 1(h)(5) and 408(m)(2) as meaning: “(A) any work of art, (B) any rug or antique, (C) any metal or gem, (D) any stamp or coin, (E) any alcoholic beverage or (F) any other tangible personal property specified by the Secretary for purposes of this subsection” which the taxpayer has held for more than one year. b.

Like Kind Exchanges – IRC § 1031 provides: “No gain or loss shall be recognized on the exchange of property held for productive use in a trade or business or for investment if such property is exchanged solely for property of like kind which is to be held either for productive use in a trade or business or for investment.” (emphasis added)

Treas. Reg. § 1.1031(a)-1(b) defines “like-kind” as having reference to the “nature or character of the property and not to its grade or quality.” Different classes of personal property are not “like kind.” Treas. Reg. § 1.1031(a)-2(a). However, examples contained in Treas. Reg. § 1.1031(a)-2(c) describe two situations are helpful: Example (1). FTC Taxpayer K exchanges a copyright on a novel for a copyright on a different novel. The properties exchanged are of a like kind. Example (2). FTC Taxpayer J exchanges a copyright on a novel for a copyright on a song. The properties exchanged are not of a like kind. Although it seems that artwork should be eligible for like-kind exchange treatment, there is scant authority to the parameters. As noted below, the IRS ruled in PLR 8127089, that for purposes of involuntary conversions under §1033, lithographs may not be replaced with artworks in “other artistic media,” such as oil paintings, watercolors, sculptures or other graphic forms of art. This suggests that the IRS could reach a similar result under §1031(a), but the scope of Section 1031 in the artwork and collectibles area is uncertain. c.

Involuntary Conversions

The involuntary conversion relief provisions of IRC § 1033 are available to taxpayers who have artwork and collectibles which are destroyed in a casualty such as a fire, flood or tornado or stolen. Selected Issues Involving Art and Other Collectibles

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Basically, IRC § 1033 provides that the taxpayer will not recognize gain if, within two years after the close of the first tax year in which any part of the gain upon the conversion is realized involuntarily converted, the taxpayer replaces the involuntarily converted property be replaced with property which is “similar or related in service or use to the property so converted.” One potential pitfall is the replacement into similar property. In PLR 8127089, the IRS denied Section 1033 treatment in part where a fire in the taxpayers' residence damaged their art collection of 3,000 lithographs, some oil paintings, pencil drawings, sculptures, masks, wood carvings and block prints. According to the ruling, the bulk of insurance proceeds were paid for damage to and loss in value of print collection; 1% was attributable to loss in value of art objects other than lithographs. Taxpayers requested a ruling that using the insurance proceeds to buy replacement property consisting of 63% lithographs and 37% art works such as oil paintings, watercolors, sculptures or other graphic forms of art qualified under Section 1033. The IRS ruled that gain would be recognized to the extent that 36% of proceeds were reinvested in art works in other artistic media. This ruling suggests that thee IRS will not consider as property “similar or related in service or use,” art work in one medium, destroyed in whole or in part, replaced with art work in another medium. However, the ruling also can be read for the proposition that, if the converted property and the replacement property are in the same artistic medium, Section 1033 will apply. 2.

Gift and Estate Tax

Federal gift tax is imposed on inter vivos transfers of property. IRC § 2501, et seq. A taxpayer’s lifetime taxable gifts are measured cumulatively. Tax is computed under a progressive rate structure with a top rate (2013) of 40%. Taxpayers are granted a credit against the tax which will effectively shield the first $5.25 million (2013 amount) of cumulative inter vivos taxable gifts. IRC §§ 2505 and 2010. Federal estate tax is imposed on estates which have a value, after certain allowed expenses and deductions, in excess of $5.25 million for decedents dying in calendar year 2013. IRC § 2001, et seq. The estate and gift tax is an integrated transfer ax system. Computationally, in very general terms, lifetime taxable gifts are added back a decedent’s estate for calculation of the estate tax due. is geared to the value of the property transferred. IRC §§ 2001 and 2010. Both the gift tax and the estate tax are measured by the value of property. Value for purposes of both taxes is “fair market value,” which is defined in Treas. Reg. §§ 20.2031-6 and 25.2512-1:

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"the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts." The fair market value sale specified by the regulations is a retail sale between a hypothetical buyer and a hypothetical seller . Treas. Reg. § 20.2031-1(b). The Internal Revenue Service requires formal appraisals of property for purposes of gift tax and estate tax purposes if the value of the property exceeds certain specified amounts. Treas. Reg. § 20.2031-6 specifies: (a) General rule. … A room by room itemization of household and personal effects is desirable. All the articles should be named specifically, except that a number of articles contained in the same room, none of which has a value in excess of $100, may be grouped. A separate value should be given for each article named. In lieu of an itemized list, the executor may furnish a written statement, containing a declaration that it is made under penalties of perjury, setting forth the aggregate value as appraised by a competent appraiser or appraisers of recognized standing and ability, or by a dealer or dealers in the class of personalty involved. (b) Special rule in cases involving a substantial amount of valuable articles. Notwithstanding the provisions of paragraph (a) of this section, if there are included among the household and personal effects articles having marked artistic or intrinsic value of a total value in excess of $3,000 (e.g., jewelry, furs, silverware, paintings, etchings, engravings, antiques, books, statuary, vases, oriental rugs, coin or stamp collections), the appraisal of an expert or experts, under oath, shall be filed with the return. The appraisal shall be accompanied by a written statement of the executor containing a declaration that it is made under the penalties of perjury as to the completeness of the itemized list of such property and as to the disinterested character and the qualifications of the appraiser or appraisers. (emphasis added) The gift tax regulations are not explicit as to art. Treas. Reg. § 25.2512-1. As noted above, both the gift tax and estate tax are measured by the value of the property transferred. Some aggressive taxpayers have attempted, for gift tax and estate tax purposes to measure the value of U. S. coins / currency at their face value, even if the numismatic or gold / silver value exceeds the face value. This tactic is both incorrect and can expose the taxpayer to tax and penalties. Both U. S. coins and currency are property. Rev. Rule 78-360, 1978-2 C.B. 228. As such, value must be the fair market value. 3.

Charitable Donations

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a.

Income Tax Purposes - General

It is important to distinguish between: (i) (ii) income property.

public and private charities; and long-term capital gain and short-term capital gain / ordinary

Public charities generally derive their support from the public. Typical examples are schools, churches, hospitals and museums. Some private foundations may qualify as public charities. The classification of a charity as public or private is determined under IRC § 509 (beyond the scope of this presentation), but the Internal Revenue Service provides a classification listing at www.irs.gov. IRS Publication 78 is no longer published. Another source is Guidestar (www.guidestar.org). Donations of long-term capital gain property to public charities can result in a charitable income tax deduction equal to the fair market value of the property donated. IRC § 170(e) . Donations to private charities are limited to basis. IRC § 170(e)(1). Donations of short-term capital gain property and ordinary income property are limited to basis. Treas. Reg. § 1.170A-4(b). As noted above, (i) property created by the donor, (ii) created for the donor and property acquired in a carry-over basis transaction from either (i) or (ii) cannot qualify as long-term capital property. Interesting example: Stephen Jones, attorney for Oklahoma City bomber Timothy McVeigh, was denied a charitable contribution of approximately $300,000 for the donation to the University of Texas of material prepared for him by the government in connection with the case. Jones had contended that he owned the case files under a number of theories. The Tax Court ruled that, under Oklahoma law, Mr. Jones did not own the materials, therefore, he was entitled to no deduction. The Tax Court then continued its analysis and concluded that the donated material—memoranda, laboratory reports, computer discs, and photographs—fell into the category of letters and memoranda created for the donor which are excluded from capital gain treatment. Taxpayer argued the material was prepared by the government for its own prosecution of the case and not for taxpayer. But the Tax Court disagreed, pointing out that copies were made, categorized, and packaged specifically for taxpayer as attorney for the defendant. Because the material was excluded from capital gain treatment and taxpayer had a zero basis in it, no deduction was allowed. The Tenth Circuit affirmed the Tax Court on the theory that the contributed property was not capital gain property resulting in a zero deduction and therefore, did not have to reach the issue of ownership of the contributed property. Jones v. Commissioner, 129 TC 146 (2007), aff’d., 560 F3d 1196 (10th Cir. 2009); cert denied, 130 S.Ct. 302 (2009). Selected Issues Involving Art and Other Collectibles

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b.

Income Tax Purposes – Related Use Requirement

Tangible personal property donated to a public charity is deductible at fair market value only if the recipient charity meets the “related use” test. The related use test requires that use of the donated property by the recipient charity be related to the purpose or function of the charity. IRC § 170(e)(1)(B)(i). This requirement is limited to property which has a fair market value in excess of $5000. If the related use test is not met, the deduction is limited to basis. A taxpayer may treat a contribution as satisfying the related use requirement if: i. The taxpayer establishes that the item of art is not actually put to an unrelated use by the charity; or ii. At the time of contribution, it was reasonable for the taxpayer to anticipate that the item of art would not be put to an unrelated use by the charity. Treas. Reg. § 1.170A-4(b)(3). Example A: A sculpture is contributed to an art museum which is a public charity and the museum actually, from time to time, publicly exhibits the sculpture. The related use test is satisfied. Example B: The same sculpture is donated to the Communities Foundation of Texas, a public charity, which receives the gift with the intention to sell it at a charity auction. The related use test is not satisfied. Treas. Reg. § 1.170A-4(b)(3). If the recipient charity disposes of the donated item within three years, the prior donation is limited to basis and recaptured. IRC § 170(e)(7). A taxpayer may protect himself from this failure of the related use test by obtaining a certification from the charity at the time of the gift that the property is intended to be put to a use related to the charities exempt purpose or was actually put to such use – Form 8282. IRC § 170(e)(7)(B). c.

Income Tax Purposes – Qualified Appraisal / Qualified Appraisal

IRC § 170(a)(1) denies a charitable deduction of property unless certain appraisal rules are followed. If the claimed value of contributed item exceeds $5,000, the appraisal rules are triggered. Treas. Reg. § 1.170A-13(c)(1). The $5,000 threshold applies to both a single item of property or to an aggregation of similar items of property donated during the calendar year, such as collections of coins, stamps, books or lithographs. For donations falling within these substantiation rules, the taxpayer must: i.

Obtain a Qualified Appraisal;

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A.

prepared by a Qualified Appraiser:

B. not earlier than sixty days before the date of the contribution nor later than the due date of the return with extensions; C.

the appraisal must be signed and dated by the Qualified Appraiser;

D. the appraisal fee cannot be based on a percentage of value of the contributed item; E.

the appraisal must contain the following: 1.

detailed description of the property;

2.

description of the physical condition of the property;

3.

date or expected date of the contribution;

4. terms of any agreement or understanding relating to the use, sale, or other disposition of the contributed property; 5. name, address, and taxpayer identification number of the appraiser; 6. detailed description of the appraiser's background and qualifications; 7. statement confirming that the appraisal was prepared for income tax purposes; 8.

date on which the property was valued;

9.

appraised fair market value of the property;

10.

method of valuation used to determine fair market value;

11.

specific basis for the valuation;; and

12. description of the fee arrangement between the donor and the appraiser. ii.

A summary of the qualified appraisal must be attached to the tax return.

iii. The appraiser must be a “Qualified Appraiser,” defined in Treas. Reg. § 1.170-13(c)(5)(i), means one:

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A. who holds himself or herself out to the public as an appraiser who is an expert as to the particular type of property being appraised; B. who understands that, if he or she makes a false or fraudulent overstatement of value, he or she may be subject to a civil penalty under section 6701; C. independent of the donor. The appraiser cannot be the donor or the donee, a party to the transaction in which the donor acquired the property, a person employed by any of the foregoing, or a person related (within the meaning of section 267 (b)) to any of the foregoing. Treas. Reg. § 1.17013(c)(5)(iv)(B).

C.

VALUATION 1.

Factors Impacting Value

The following factors will impact the fair market value of art and collectibles: a.

Provenance

The International Foundation for Art Research (“IFAR”) describes “provenance” in it guide: What Is Provenance? “…The provenance of a work of art is a historical record of its ownership, although a work’s provenance comprehends far more than its pedigree. The provenance is also an account of changing artistic tastes and collecting priorities, a record of social and political alliances, and an indicator of economic and market conditions influencing the sale or transfer of the work of art. An ideal provenance history would provide a documentary record of owners’ names; dates of ownership, and means of transference, i.e. inheritance, or sale through a dealer or auction; and locations where the work was kept, from the time of its creation by the artist until the present day. Why is Provenance Research Important? For Authenticity: Provenance can bolster claims of a work’s authenticity. Inventory records of an object’s presence in a particular collection or in Selected Issues Involving Art and Other Collectibles

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the artist’s purported workshop provide strong evidence of a work’s authenticity. Art forgers, however, often falsify information establishing the provenance of a work of art— forging receipts of sale, ownership marks, dealers’ records, exhibition labels, and collectors’ stamps. For this reason, provenance history is seldom accepted as the sole proof of authenticity for a work of art. For Valuation: As a factor in establishing authenticity, a complete ownership history adds value to a work of art. Similarly, a distinguished provenance, recording the work in the collection of a prominent owner or collection, may have a positive impact on the work’s value. Conversely, the absence of a provenance record may raise questions not only about the legal title, but about the attribution or authenticity of a work, particularly in the case of an artist whose life and work are well documented. For Ownership: An established provenance can help document proof of ownership if legal title is contested. Transaction records and other proofs of sale or transfer of ownership may help determine the legitimacy of a sale or provide a defense in repatriation claims. In some cases, the presence of a “red flagged name” in the provenance may indicate that an artwork was stolen, subjected to a forced sale, or otherwise misappropriated during the Nazi era, thus warranting further research. See the Art Law and Cultural Property section of IFAR’s Website for examples of legal cases where provenance, or lack thereof, was a factor.” b.

Rarity

“Rarity is determined by the frequency with which a work by an artist appears on the market, or the number of a specific type of work that is currently available from a particular period in an artist’s career. When combined with demand, rarity becomes very important in appraisal. Visiting Picasso’s career can again be helpful in demonstrating this fact. A naturalistic or figurative Picasso painting from the turn-of-the-(twentieth)-century is extremely rare, compared to a similarly figurative work from the 1920s. Works from the earlier era, referred to as his “Blue Period” – due to the heavy usage of blues and darker, more dramatic hues – rarely come to market. In addition, they are in demand by museums and important collections. Because of these two combined factors, rarity and demand, when a Blue Period painting does appear for sale, its price is very high.” www.artnet.com

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c.

Quality

The intrinsic quality of a work determines whether a piece will retain or increase its value over time, independent of current fashion or economies. d.

Condition

According to the IRS Publication 561, physical condition and the extent of restoration are important factors in determining value. An antique in damaged condition may be worth significantly less than a comparable item in excellent condition. Has the object been maintained in the same condition since its creation? If there are changes in the condition, what are they? Have they affected the structure of the object? Have they affected the appearance of the object? Has the object been restored since its inception? If so, has the original integrity of the work been upheld? www.artnet.com e.

Fashion

Items which are currently popular or fashionable may be worth more that the item may have been worth at a time when the item was less popular or fashionable. 2.

Finding a Qualified Appraiser

When seeking an appraiser, seek one (i) familiar with the Internal Revenue Service requirements for appraisals, (ii) with experience valuing the type of item in question and (iii) who has appropriate professional credential such as Appraiser with USPAP, ASA, ISA or AAA. 3.

Finding a Purchaser

If a work of art or collectible is being sold, there are a number of types of vehicles to facilitate that transaction: i.

Garage sales for low value items;

ii.

Consignments or Estate Sales

iii. Auctions for larger value items. There are a number of national and local auction houses.

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Selected Issues Involving Art and Collectibles Dallas Bar Association Probate Trusts and Estates Section November 26, 2013 Presented By Norman A. Lofgren

Looper, Reed & McGraw, P.C.

Mark Prendergast & Karl Chiao Heritage Auctions

According to the IRS: “art” includes “paintings, sculptures, watercolors, prints, drawings, ceramics, antiques, decorative arts, textiles, carpets, silver, rare manuscripts, historical memorabilia, and other similar objects”

According to the Internal Revenue Code: “Collectibles” mean: a. any work of art, b. any rug or antique, c. any metal or gem, d. any stamp or coin, e. any alcoholic beverage or f. any other tangible personal property specified by the Secretary

JUNK or TREASURE?

SITUATIONS INVOLVING COLLECTIBLES

SITUATIONS INVOLVING COLLECTIBLES • • • • •

Death of Owner Gifts by Owner Sales by Owner Charitable Donations Casualty Losses

TAX IMPLICATIONS AND RULES •Income Taxation – Capital Assets • “property held by a taxpayer (whether or not connected with his trade or business).”

TAX IMPLICATIONS AND RULES

• Income Taxation – Capital Assets • expressly excluded are “a copyright, a literary, musical or artistic composition, a letter or memorandum, or similar property, held by (A)

(B) (C)

a taxpayer whose personal efforts created such property, taxpayer for whom such property was prepared or produced, or taxpayer in whose hands the basis of such property is determined … in whole or part by reference to the basis of such property in the hands of a taxpayer described in subparagraph (A) of (B).”

TAX IMPLICATIONS AND RULES • Income Taxation • Sales • 28% tax rate on “collectibles gain” • taxpayer must have held the collectible for more than one year. •

TAX IMPLICATIONS AND RULES • Income Taxation • Like-Kind Exchanges •Art and Collectibles which are capital assets eligible for like-kind exchange treatment •Needs to be same artistic medium

TAX IMPLICATIONS AND RULES

• Income Taxation • Like-Kind Exchanges • Definition of “like-kind” not well defined • Treas. Reg. § 1.1031(a)-2(c) examples: • Example (1). Taxpayer K exchanges a copyright on a novel for a copyright on a different novel. The properties exchanged are of a like kind. • Example (2). Taxpayer J exchanges a copyright on a novel for a copyright on a song. The properties exchanged are not of a like kind.

TAX IMPLICATIONS AND RULES • Income Taxation

• Involuntary Conversions • Art and collectibles can be eligible for deferral of gain following an involuntary conversion, e.g., fire destroys painting and insurance proceeds used to purchase new painting • BUT replacement property must be “similar or related in service or use

TAX IMPLICATIONS AND RULES • Income Taxation

• Involuntary Conversions • Different artistic mediums will not qualify

TAX IMPLICATIONS AND RULES

• Gift and Estate Tax • Federal Gift Tax is imposed on inter vivos transfers of property. • Lifetime taxable gifts are measured cumulatively • Tax is computed under a progressive rate structure with a top rate (2013) of 40%. • Taxpayers are granted a credit against the tax which will effectively shield the first $5.25 million (2013 amount) of cumulative inter vivos taxable gifts.

TAX IMPLICATIONS AND RULES • Gift and Estate Tax • Federal Estate Tax is imposed on estates which have a value, after certain allowed expenses and deductions, in excess of $5.25 million for decedents dying in calendar year 2013.

TAX IMPLICATIONS AND RULES

• Gift and Estate Tax • The estate and gift tax is an integrated transfer ax system. Computationally, in very general terms, lifetime taxable gifts are added back a decedent’s estate for calculation of the estate tax due. is geared to the value of the property transferred. • Both the gift tax and the estate tax are measured by the value of property. Value for purposes of both taxes is “fair market value” • Retail not wholesale

TAX IMPLICATIONS AND RULES

• Gift and Estate Tax • Appraisal required if •there are included among the household and personal effects articles having marked artistic or intrinsic value of a total value in excess of $3,000 (e.g., jewelry, furs, silverware, paintings, etchings, engravings, antiques, books, statuary, vases, oriental rugs, coin or stamp collections), the appraisal of an expert or experts, under oath, shall be filed with the return.

TAX IMPLICATIONS AND RULES

• Gift and Estate Tax • Appraisal •The appraisal shall be accompanied by a written statement of the executor containing a declaration that it is made under the penalties of perjury as to the completeness of the itemized list of such property and as to the disinterested character and the qualifications of the appraiser or appraisers.

TAX IMPLICATIONS AND RULES • Income Tax Charitable Donations of Art and Collectibles •Strict rules if value exceeds $5,000

Specific IRS Requirements for Charitable Donations of Art Donate long-term capital gain items Donate to Public Charity and get acceptance Charity must have a “related” or “like” use for the items

TAX IMPLICATIONS AND RULES • Interesting Case on issue of long-term capital gain property: •Jones v. Commissioner, 10th Cir. 2009

•Stephen Jones, attorney for OKC bomber Timothy McVeigh denied a $300K charitable deduction for memoranda, laboratory reports, computer discs, and photographs produced to him by government in the Mc Veigh trial. • copies were made, categorized, and packaged specifically for taxpayer as attorney for McVeigh – not long term capital gain property

Retain Qualified Appraiser Get a Qualified Appraisal Report Meet your deadlines Know when you need an appraisal and second opinion

Valuation and the Marketplace

The Art and Collectibles Market

Specialty markets –the right expertise for proper valuations.

Factors that affect the value of property Provenance Rarity Quality Condition Fashion

Provenance

Wayne Auction

Rarity

Quality

Condition

0.5 grade

$850,000

$6,500

Fashion:

Trends and Styles

Combination of Factors

VALUATION AND THE MARKETPLACE Auction Estimate $100,000 to $150,000

vs.

Appraisal $125,000 Fair Market Value $ 200,000+ Replacement Cost

True Value

= Sold for $110,000

Planning for a Collection

Get an Accurate Assessment of Value - Dealers, auction houses, research -

Know what type value given – Antique Roadshow syndrome Fair Market or Retail Replacement Value

Need for formal written appraisal? - Charitable Donation - Financial/Estate Planning - Gift Tax - Equitable Distribution - Insurance - Estate Tax

Helping Heirs, Executor and Beneficiaries - Inventory of collection: locations, related paperwork, note items of value - Sell during owner’s lifetime? easier to distribute money, less burden on family/executor, they can keep collecting!

Finding a Qualified Valuation Expert •Appraiser with USPAP certification •Knowledgeable of IRS requirements •Member of recognized appraiser society •ASA, ISA, AAA • Auction houses or appraisal society websites – Appraisal Services Department • Costs of appraisals

How Do I Dispose of the Art / Collectible •Garage Sale or donate low value items •Auctions •Consignments or Estate Sales •Major players in the marketplace •tiers of auction sales •National vs. local auctions •Get sale proposals