e Motherwell painting, a 66- by 50-inch oil on canvas work created in 1966, was acquired by Ms. Newberger in 1969 for $8,000. Using the 2010 sale of Motherwell's In Black and White No. S (a work similar in size, composition, and date of creation) for $1,426,500 as a comparable, the Estate's valuation expert

e Motherwell painting, a 66- by 50-inch oil on canvas work created in 1966, was acquired by Ms. Newberger in 1969 for $8,000. Using the 2010 sale of Motherwell's In Black and White No. 5 (a work similar in size, composition, and date of creation) for $1,426,500 as a comparable, the Estate's valuation expert

sale of the Picasso renders their valuation wholly unreliable. ... We agree with [the IRS's] expert." Motherwell Painting In examining the sale of Motherwell's In Black and White No.5 painting some 16 months after the date of death, the Court noted that, at the date of sale, "the artwork market had largely