More than 20 years after the death of billionaire art dealer Daniel Wildenstein, his estate has settled with a dispute with the IRS. The family will have to pay some $17 million in taxes.

Wildenstein was the heir to an important family of art collectors and dealers who founded the gallery Wildenstein & Co. in 1875. A dispute over the family’s assets, including thousands of works of art, embroiled them in many tax lawsuits in their native France.

The IRS had been involved in the settling of Daniel Wildenstein’s estate after filing for an owed tax deficiency in 2018. It argued that the estate tax the Wildenstein family originally paid upon the death of Daniel was inaccurate, as it only accounted for a small portion of Wildenstein’s assets in the U.S.

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In tax documents from 2018 that were obtained by ARTnews, the Wildenstein family said they had submitted their taxes without having a full appraisal of the works and agreed to a penalty for negligence. However, the appraisal they received from Sotheby’s corrected the IRS’s valuation of some 393 works of art from $215 million to just $45 million. The estate added 10 works to the tax plan that it said were owned by Wildenstein in the U.S. and subtracted 29 others that it said were not owned by Wildenstein.

According to the IRS, the estate tax should have also included works in Wildenstein’s trust as well as works that had resided for many years in the U.S., even if they were in storage outside of the country when Wildenstein died. These works later made their way back to the States.

A representative for Wildenstein’s estate did not respond to requests for comment.

Some experts said that the IRS’s argument raises new questions about how U.S. borders function with regard to taxable assets.

“Taxable tangible movable property is something that has long been regarded as that which is physically resident in the United States,” said Thomas Giordano, a partner at the Los Angeles–based firm Karlin & Peebles LLP who specializes in estate taxes. “But what the IRS was trying to argue is that the situs of a non-U.S. person’s assets has a sort of subjective domicile,” meaning that one could effectively debate where a work resides by relying on factors other national borders.

The IRS invoked the French-U.S. tax treaty to argue for a point made by the French tax code. Per that code, works held in storage are technically seen as being in transit and thus their residence is up for debate.

It also claimed that that many artworks Wildenstein held in his trust, called the Delta Trust, had not been accounted for. Delta contained nearly 2,500 works of art.

At some point, the IRS believed that they were owed some $200 million in taxes, but the settlement’s conclusions have the Wildenstein family paying $17 million in taxes after the US Tax Court ascertained that 258 works of art worth $30,969,660 counted as residing in the US. The family will also pay $557,627 in fines.