“This is the death of fractional gifts,” Manhattan art assets advisor Ralph E. Lerner told the New York Times in 2006, just a few weeks after Congress enacted the Pension Protection Act, which (among other provisions) placed certain limits on the length of time that collectors may take deductions for their gifts of high-value artworks to museums, as well as not permitting these donors to increase the deduction they take over time based on the artworks’ escalating value.

Fractional gifts didn’t die and continue to be a normal way that donors may receive the full tax benefit of valuable objects (charitable gifts are deductible only up to the limit of 30 percent of the donor’s annual income), but don’t judge Lerner too harshly. Lots of museum directors, the advocacy groups for museums and museum directors, the lawyers for wealthy collectors, and plenty of others all screamed bloody murder back in 2006. “[T]he necessity to complete the gift in a ten-year period is a serious impediment to donors making substantial gifts,” Gail Andrews, director of the Birmingham Museum of Art and one-time president of the Association of Art Museum Directors, wrote to John Lewis, then chairman of the House Ways and Means Oversight Subcommittee in 2007. Do something! New York senator Charles Schumer and then New Mexico representative Tom Udall heard the call and introduced bills in Congress to right this great wrong. (“In trying to close a tax loophole, the Pension Protection Act suffocated a time-honored method of giving that has made many of our national treasures available to the public,” Udall announced.)