The IRS’s Dirty Dozen and Other Woes for Overvalued Art Donations

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The IRS’s Dirty Dozen and Other Woes for Overvalued Art Donations

April 13, 2026

TAX NOTES FEDERAL

Congress and the IRS have raised the alarm for decades over what they call “charitable contribution tax shelters.”  Recent focus has been on art donations, where the IRS is using various approaches to halt what it considers improper tax positions regarding art ownership and valuation.  For instance, the IRS has issued a public warning, imposed promoter penalties, engaged in Tax Court litigation, and placed art donations on its Dirty Dozen list for 2026.  This article by Partner Hale Sheppard describes the procedures the IRS is currently using to challenge organizers, taxpayers, appraisers, and/or charities.

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halesheppard@eversheds-sutherland

Hale E. Sheppard

Partner

Atlanta, United States

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