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attending college, Carroll worked in the gallery. Carroll
returned to the gallery in 1964 and worked there until it closed.
Conrad also worked in the gallery for a period of time.
Determining the Value of the Gallery and Its Collection for
Purposes of Sidney’s Estate Tax Return
Sidney’s estate filed a Form 706, United States Estate (and
Generation-Skipping Transfer) Tax Return, on February 28, 1991.
George J. Noumair prepared the Form 706. On the Form 706, the
value of the gallery was reported to be $19,533,750. This amount
included a discounted value of $12,403,207 for the 464 works of
art (the collection) that the gallery owned on the date of
Sidney’s death, cash and cash equivalents of $8,171,302, and
liabilities of $1,040,759.
In order to determine the value of the gallery for estate
tax purposes, Sidney’s estate employed Sotheby’s to prepare an
appraisal of the collection. Sotheby’s explained the basis for
its appraisal as follows:
In accordance with your request, we have appraised
the works of art owned by the Sidney Janis Gallery,
with a view towards determining the fair market value
thereof as of May 23, 1990, six months after the date
of death of Sidney Janis. * * * We have valued these
works on an item-by-item basis at fair market value.
* * *
* * * * * * *
Despite the large number of works held by the
Gallery, we have not taken into account any overall
dimunition [sic] in value which might occur if the
entire holdings were to be placed for sale in the
ordinary course in the market at one time, which is the
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