Michelle Petock is a senior counsel in Holland &
Knight's
Miami office.
An interesting tax case involving an enviable collection of art
is currently pending in federal court in Texas. The collection,
which caught the attention of the Internal Revenue
Service after the death of banking and media mogul Joe
Allbritton in 2012, includes a portfolio of Impressionist and
Post-Impressionist paintings. The collection includes works by Paul
Cezanne, Winslow Homer, Marc Chagall, Paul Gauguin, Claude Monet,
Vincent van Gogh and Pablo Picasso.
Barbara Allbritton, widow of Mr. Allbritton, has sued the United
States in her individual capacity and as representative of her late
husband's estate, to recoup approximately $40.6 million in
taxes and interest which she claims have been paid "under
protest." The IRS asserts that the corporation owned by Mr.
Allbritton and members of his family, or trusts for their benefit,
made an outright "constructive property distribution" to
Mr.
