What Is The Fair Market Value of Something That Cannot be Sold?

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That's the question that lawyers of the heirs of New York art dealer Ileana Sonnabend and the IRS are arguing in this Catch-22 case involving artwork by Robert Rauschenberg:

Because the work, a sculptural combine, includes a stuffed bald eagle, a bird under federal protection, the heirs would be committing a felony if they ever tried to sell it. So their appraisers have valued the work at zero.

But the Internal Revenue Service takes a different view. It has appraised “Canyon” at $65 million and is demanding that the owners pay $29.2 million in taxes.

“It’s hard for me to see how this could be valued this way because it’s illegal to sell it,” said Patti S. Spencer, a lawyer who specializes in trusts and estates but has no role in the case.

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Except that isn't a bald eagle, or at least it doesn't appear to be - bald eagles have white heads, hence the whole "bald" part. I found a larger copy and it looks to possibly be a golden eagle.
Either way, it is an illegal bird to kill or have parts of...
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