Rev. Proc. 96-15 outlines how taxpayers can request from the IRS a statement of value that can be used to substantiate the value of art for income, estate or gift tax purposes. Taxpayers who comply with this revenue procedure may rely on the statement of value in completing their income, estate or gift tax return that reports the transfer of art. Its provisions include the following:
 The procedure applies to items appraised at $50,000 or more. The Service may issue a statement of value for items less than $50,000 if the request includes at least one item of $50,000 or more.
 The user fee is $2,500 for up to three items and $250 for each additional item.
 As part of the request, the taxpayer must submit an appraisal that meets the requirements outlined in the procedure. Additional information required with the request is detailed in the procedure.
 A taxpayer may withdraw the request at any time before it is issued by the IRS. The...