• <b>19th Century Shop:</b> Charles Darwin on sexuality and the transmission of hereditary characteristics: Autograph Letter Signed to Lawson Tait. Down, 17 January [1877].
    <b>19th Century Shop:</b> MILTON, JOHN. <i>Paradise Lost. A Poem written in ten books.</i> London: 1667. A very rare example with the contemporary binding untouched and with a 1667 title page.
    <b>19th Century Shop:</b> Hamilton secures the ratification of the Constitution: <i>The Debates and Proceedings of the Convention of the State of New-York, assembled at Poughkeespsie, on the 17th June, 1788.</i>
    <b>19th Century Shop:</b> The social contract “Man is born free, and everywhere he is in chains”: ROUSSEAU, JEAN-JACQUES. <i>Principes du Droit Politique [Du Contract Social]</i>. Amsterdam: Michel Rey, 1762
    <b>19th Century Shop:</b> “The first English textbook on geometrical land-measurement and surveying”: BENESE, RICHARD. <i>This Boke Sheweth the Maner of Measurynge All Maner of Lande…</i>
  • <b>Bonhams: History of Science and Technology. Wednesday, December 6, 2017. New York</b>
    <b>Bonhams, Dec. 6:</b> Lot 95. Turing. <i>Systems of Logic Based on Ordinals</i>. Offprint. London, 1939. Robin Gandy's Copy. $20,000 to $30,000
    <b>Bonhams, Dec. 6:</b> Lot 98. Zernike, Fritz. The 1953 Nobel Prize for Physics: The Invention of the Phase-Contrast Microscope. $100,000 to $150,000
    <b>Bonhams, Dec. 6:</b> Lot 111. Apple 1 Computer, operational, with exceptional provenance. $400,000 to $600,000
    <b>Bonhams: Voices of the 20th Century. Wednesday, December 6, 2017. New York</b>
    <b>Bonhams, Dec. 6:</b> Lot 1074. Bruce, Lenny. An unreleased 16 mm film by "Count" Lewis DePasquale featuring Lenny Bruce. $7,000 to $10,000
    <b>Bonhams, Dec. 6:</b> Lot 1254. Hirohito. Manuscript in Japanese, "The Emperor's Monologue," transcribed by Terasaki Hidenari. $100,000 to $150,000
    <b>Bonhams, Dec. 6:</b> Lot 1095. Goldman. Emma. Large archive of correspondence, much of it to Warren Starr Van Valkenburgh. $70,000 to $100,000
    <b>Bonhams: History of Science and Technology. Wednesday, December 6, 2017. New York</b>
    <b>Bonhams, Dec. 6:</b> Lot 109. Wozniak and Jobs. The First Digital "Blue Box", Berkeley, 1972. $30,000 to $50,000
    <b>Bonhams, Dec. 6:</b> Lot 46. Newton, Isaac. <i>Philosophiae naturalis principia mathematica</i>. 1st issue. London, 1687. $300,000 to $500,000
    <b>Bonhams, Dec. 6:</b> Lot 49. Newton. Autograph Manuscript in English, a portion of a draft of Newton's study on revelation. $15,000 to $20,000
    <b>Bonhams: Voices of the 20th Century. Wednesday, December 6, 2017. New York</b>
    <b>Bonhams, Dec. 6:</b> Lot 1027. Fitzgerald, F. Scott. The Great Gatsby. 1st edition, 1st issue. Scribners, 1925. $40,000 to $60,000
    <b>Bonhams, Dec. 6:</b> Lot 1042. Hemingway., Ernest. For Whom the Bell Tolls. Presentation copy, one of 15 copies. Scribners, 1940. $25,000 to $35,000
    <b>Bonhams, Dec. 6:</b> Lot 1215. A 48-star American Flag, flown from LCT-703, sunk on Omaha Beach, December 1944. $15,000 to $20,000
  • <b>Announcing a new Books for Sale platform hosted by Biblio!</b>
    <b>List your books simultaneously on Rare Book Hub and Biblio!</b>
  • <b>Sotheby’s New York: Fine Books & Manuscripts. December 11, 2017</b>
    <b>Sotheby’s NY, Dec. 11:</b> Wright, Frank Lloyd. An important collection of early letters from Wright to members of his family. 1909–1926. $60,000 to $80,000
    <b>Sotheby’s NY, Dec. 11:</b> Rand, Ayn. Ayn Rand's important first speech delivered at the Ford Hall Forum. $60,000 to $80,000
    <b>Sotheby’s NY, Dec. 11:</b> Tolkien, J.R.R. <i>The Hobbit or There and Back Again</i>. London: George Allen & Unwin Ltd., 1937. $50,000 to $70,000
    <b>Sotheby’s NY, Dec. 11:</b> [Flemish Flower Manuscript]. Lille, Spanish Netherlands: 1630. $50,000 to $60,000
    <b>Sotheby’s NY, Dec. 11:</b> García Márquez, Gabriel. Two drafts of an early short story, "Rosas Artificiales.” $40,000 to $60,000
    <b>Sotheby’s New York: History of Science and Technology. December 12, 2017</b>
    <b>Sotheby’s NY, Dec. 12:</b> Enigma M4. A Fully Operational Four-Rotor ("M4") Kriegsmarine Enigma Cipher Machine, 1944. $350,000 To $500,000
    <b>Sotheby’s NY, Dec. 12:</b> The "Polio" Nobel Prize. The 1954 Nobel Prize Medal for Physiology or Medicine Awarded to Frederick C. Robbins. $200,000 to $300,000
    <b>Sotheby’s NY, Dec. 12:</b> ENIGMA I. A Fully Operational Early Three-Rotor Enigma I Cipher Machine. Berlin, Heimsoeth Und Rinke, Early 1930s. $120,000 to $180,000
    <b>Sotheby’s NY, Dec. 12:</b> Bonestell, Chesley. "Saturn, Viewed From Titan, One of Its Satellites." A Mid 1950's Study for the 360° Titan Panorama. 1 ½ x 20’. $100,000 to $150,000
    <b>Sotheby’s NY, Dec. 12:</b> Descartes, René. <i>Discours de la Méthode pour Bien Conduire Sa Raison, & Chercher la Verité dans les Sciences... 1637. $80,000 to $120,000

Rare Book Monthly

Articles - November - 2014 Issue

How Can Collectors Save $14 Million on Their Estate Taxes?

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Well, for starters, you better begin with a lot of money. A recently decided appeals court case has been labeled a major victory for wealthy collectors with regards to reducing their estate tax liability. A $14 million judgment against the IRS can elicit a giddy response. Nonetheless, we recommend a dose of caution be taken by those who may see this as a slam dunk for high end collectors. Not everything is quite so cut and dried, and every estate is unique.

 

This notable case involved works of art, but there is no reason why it would not apply to books or other valuable collections. Lawyers, and we should all be thankful for lawyers, have found many ways for people of means to legally avoid part of their tax liability. If you have enough money to be subject to significant estate tax liability, you likely have sought out professional advice already, but if not, and you own valuable “collectibles,” here is a case of which you should be aware. But, please do not make any decisions based on this brief review. Seek professional help now!

 

James A. Elkins, Jr., died in 2006. His wife predeceased him. He was a very wealthy man. Mr. Elkins also had access to the best legal advice. His father was a founder of Vinson & Elkins, a law firm based in Houston but with offices all over the world. It is one of the nation's most prestigious law firms. Mr. Elkins was also an art collector, owning a few very valuable pieces of art, and many others of significant, though more modest value. Many pieces were hanging from the walls of his Houston home.

 

At this point we should note two of the ways you can reduce the amount of estate tax you owe. Mr. Elkins used both. One is to transfer some of that estate to others before you die. The other is to show why the assets in your estate are worth less than people might think. The lower the value of your estate, the less it will have to pay in taxes when you die.

 

In 1990, Mr. Elkins created a trust that effectively gave his 50% interest in three very valuable works to his children. Texas is a community property state, which means that (for the most part) each spouse owns a 50% share of the couple's property. When Mrs. Elkins died, he got back her 50%, but he did something else with her 50% share of the other 61 pieces of art. Those 61 would have gone to Mr. Elkins, and he would not have paid any estate tax. Transfers to your spouse on death are not subject to estate tax, but transfers to anyone else are. However, all of the value of those 61 pieces of art would have been subject to tax later when Mr. Elkins died.

 

Now, there is an exemption from estate tax for a significant amount of money. This is why the average person's estate is not subject to tax. Currently, that amount is a little over $5 million, though it was considerably less when Mrs. Elkins died in 2000. Nonetheless, Mrs. Elkins' exemption was about to be wasted. So, Mr. Elkins declined his wife's bequest of a portion of her 50% interest in those other 61 works of art, allowing it to go the secondary heirs, their children, instead. He declined just enough to fully use up her estate tax exemption, but not enough to generate any tax liability. This way, there would be less in his estate to tax when he died. The result was that each of his three children immediately received an 8.98167% interest in each of the 61 pieces of art. Yes, we are serious about that share percentage.

 

Now, you may wonder why Mr. Elkins didn't just give each child a couple of paintings until enough was given to reach the exemption threshold. The reason is that Mr. Elkins, or his lawyers, were way too savvy for that. They were creating something called a “fractional ownership” in each piece, and eventually, this would end up saving the kids $14 million. This is why, if you are wealthy, you need a good tax lawyer.

 

The parties (father and children) then did a few more things. They signed an agreement saying none of them could sell their fractional interests in the art without the consent of all of the others. They also created the terms of how they would “share” the art. Each party was entitled to hang the art on their wall for a percentage of the year based on their percentage of ownership. To exercise this right, they had to give the current possessor 30 days notice and pay all expenses in moving the art. So, one of the offspring could possess these items for 33 days per year, providing he/she wanted to pay the expenses involved in moving 64 pieces of valuable artwork. Not surprisingly, and to keep this an “arm's length” transaction, the children all agreed to lease their 33 days worth back to their father so they could remain on his wall.

 

Now if all this sounds like insanity, there is a reason for this madness. Its name is “fractional share discount.” It is a concept widely known among the very wealthy and their lawyers, though perhaps not by most others. It applies to all sorts of things – real estate, a family business, and art. What it says, in effect, is that the sum of the parts aren't worth as much as the whole. Here is how it works. Items in an estate are valued for tax purposes based on the market value – the price a free and independent buyer and seller would exchange to buy or sell the item. To determine the fair market value, the estate hired an appraiser from Sotheby's. Independent transactions take place at Sotheby's practically everyday. All parties, including the IRS, agreed his values were fair.

 

Now, here is where the fractional discount comes into play. Say one of these paintings was fairly valued at $10 million. What is an 8.98167% share of it worth? Did you say $898,167? Guess again. Courts have regularly said no. It is less. What can you do with this fractional share? You have no real control over the art. If you bought it, you would have to deal with the co-owners. Ideally, you would all get together to sell your interests jointly, so that the painting could be sold for the $10 million it is worth. However, one of the children testified that all three of them so liked these works, and they had such deep sentimental value, that there was no way they would ever part with their shares. On top of that, there was an agreement requiring all owners agree to a sale, each one having a veto power. Anyone buying a fractional share would have their money tied up, and no practical way to sell what they had purchased. And, if the fractional owner wanted to hang the art on his walls, the cost of yearly shipping for limited use would be prohibitive. Naturally, those shares are worth far less than $898,167 in the open market. The estate's appraiser said 50% - 80% less. That in turn means the estate is worth less and the estate tax it must pay is less.

 

Think about it. No art dealer is going to agree to sell such an interest in their gallery. One of the estate's witnesses testified that no auction house would sell such a fractional interest either. This is why the estate's valuation expert witness testified that the market value of the artworks, because of these fractional ownerships, was 50% - 80% less than it would be if held by a single owner.

 

The estate next brought in a legal expert who estimated the cost of legal help to go to court to try to force a sale because of the divided ownership. He estimated that would cost a ton of money, and for most of the works, the cost of forcing a sale was more than the value of the pieces themselves.

 

The IRS put all its eggs in one basket, a decision that turned out to be a mistake. It argued against the concept of a fractional share discount. Their argument, in a sense borrowed from the estate's claim, was that there was no recognizable market for fractional shares, since they never come up for sale at auction or elsewhere. Therefore, it reasoned, the standard valuation, as presented by the Sotheby's expert, should prevail, but with no discount for the ownership being divided. The first court to hear the case, the U.S. Tax Court, disagreed, and upheld the legitimacy of fractional share discounts. However, it then threw the Elkins' daughter's testimony back at the estate. She had testified how the children would never part with the artwork. The court took that perhaps a bit more seriously then the estate would have liked. They concluded that, if the children loved the art so much, they would pay up to be able to fully control it, and prevent the possibility of an outside fractional owner forcing a sale. Therefore, the Tax Court concluded the estate was only entitled to a 10% discount for the ownership being divided, rather than the 50% - 80% their expert had testified.

 

The Elkins' estate appealed the Tax Court's ruling to the Fifth Circuit U.S. Court of Appeals, and it is their ruling that has tax lawyers abuzz. The Appeals Court overturned the Tax Court decision. It upheld the part about fractional share discounts being legitimate, but overturned the 10% amount. Instead, it opted for the far greater discounts proposed by the estate.

 

While the Appeals Court felt the large discounts sought by the estate were “eminently correct,” which should hearten wealthy collectors and their lawyers, that wasn't the reason behind the reversal. They concluded that a legal case must be determined by the evidence presented. There was no evidence to support the 10% discount – the Tax Court just made that figure up based on its own beliefs of what is reasonable. The only evidence of value presented was that provided by the estate. The IRS, relying entirely on having the concept of fractional discount rejected, gave no evidence of what it believed a correct fractional discount would be. The estate's evidence of an appropriate discount went unrefuted. Since it was not, in the Appeals Court's eyes, an unreasonable amount, the Court concluded it had no choice but to accept the estate's conclusion. Slam dunk? For the Elkins' estate yes, but for the next case, not so fast.

 

Next time, the IRS can be expected to present its own estimate of a fair fractional discount, and it is likely to be less than 50% - 80%. It is unlikely the next estate will get a free pass. The Fifth Circuit Appeals Court may have found the discount “eminently correct,” but perhaps they would have been less certain if a reasonable contrary opinion were raised. Besides which, these cases are usually heard in Tax Court first. These judges deal with nothing but tax cases, and perhaps have a more jaundiced eye towards lawyerly schemes. Certainly, there was no purpose to this bizarre, convoluted transaction other than to reduce taxes. Courts tend to prefer a transaction have some legitimate other purpose. So, while there is nothing to lose and at least something to gain from sharing ownership of valuable collectibles with your heirs, you should not assume the discounts will always be quite so large. Maybe they will, and maybe they won't.

 

This case really should have been brought before Judge Judy. She would have had a more commonsense solution, like the one King Solomon applied so many years ago. If they don't want to pay their taxes, let the kids hang their 8.98167% of each painting on the wall.


Posted On: 2014-11-18 21:30
User Name: Fattrad1

Bruce,

You just wasted a lot of your readership's time. As you noted, the next cases before the IRS and the tax court will have additional evidence presented and tried differently. This article, while interesting, was a waste of bandwidth.

Jeff Elfont CPA
Swan's Fine Books


Rare Book Monthly

  • <b>Les Collections Aristophil:<br>December 20, 2017</b>
    <b>Collections Aristophil, Dec. 20:</b> SAINT-EXUPERY, ANTOINE DE. Kodachrome Film (16mm) showing Antoine de Saint-Exupery and Consuelo on a boat, 1942. JOINED: Guestbook for the Boat, signed, with a drawing of the Little Prince. 15 000 to 20 000 €
    <b>Collections Aristophil, Dec. 20:</b> CANDEE, HELEN CHURCHILL. Autograph manuscript. TITANIC, 40 leaves. Original account of the most famous shipwreck, by a survivor of the ordeal. 300 000 to 400 000 €
    <b>Collections Aristophil, Dec. 20:</b> TITANIC. Collection of 7 documents relating to the shipwreck of the Titanic (14 April 1912). 20 000 to<br>30 000 €
    <b>Les Collections Aristophil:<br>December 20, 2017</b>
    <b>Collections Aristophil, Dec. 20:</b> DUPLEIX DE CADIGNAN, JEANBAPTISTE. Signed autograph manuscript. Thirty years of memoirs related to military services and important information on the American War of Independence.<br>40 000 to 50 000 €
    <b>Collections Aristophil, Dec. 20:</b> CURTIUS. Faiz et Conquestes d'Alexandre [Histoire d'Alexandre le Grand]. In French, illuminated manuscript on paper and parchment, 16 large miniatures. 300 000 to<br>500 000 €
    <b>Collections Aristophil, Dec. 20:</b> NELSON, HORATIO. Signed autograph letter, ‘Nelson & Bronte,” aboard the Amazon, 14 October 1801, addressed to Sir William Hamilton. 4 000 to 5 000 €
    <b>Les Collections Aristophil:<br>December 20, 2017</b>
    <b>Collections Aristophil, Dec. 20:</b> GIROLAMO FRANCESCO MARIA MAZZUOLI DIT LE PARMESAN. Le couple amoureux. Pen and brown ink. 80 000 to 120 000 €
    <b>Collections Aristophil, Dec. 20:</b> SADE, DONATIEN-ALPHONSE-FRANÇOIS, MARQUIS DE. Autograph manuscript. The 120 Days of Sodom, or the School of Libertinage, 1785.<br>4 000 000 to 6 000 000 €
    <b>Collections Aristophil, Dec. 20:</b> MIRÓ, JOAN. Signed autograph correspondence to Thomas and Diane Bouchard (1949-1976). 50 000 to 60 000 €
    <b>Les Collections Aristophil:<br>December 20, 2017</b>
    <b>Collections Aristophil, Dec. 20:</b> BALZAC, HONORÉ DE. Signed autograph manuscript, Ursule Mirouët, [1841]. One of only two manuscripts of novels by Balzac in private hands. 800 000 to<br>1 200 000 €
    <b>Collections Aristophil, Dec. 20:</b> LENOIR, ALEXANDRE. Essai sur l'histoire des arts en Egypte pouvant servir d'appendice au grand ouvrage de la Commission. autograph manuscript with numerous additions and corrections. 40 000 to 50 000 €
    <b>Collections Aristophil, Dec. 20:</b> SCHRÖDINGER, ERWIN. Autograph manuscript [Spring 1946, sent to Albert Einstein]. 1 500 to 2 000 €
  • <b>Bloomsbury Auctions: Books and Works on Paper, including Fine Photographs. December 14, 2017</b>
    <b>Bloomsbury, Dec. 14:</b> Rowling (J.K.). Hogwarts School of Witchcraft and Wizardry, original fine black pen and ink manuscript book by the author J.K.Rowling, with 31pp of text and illustrations. £80,000 to £120,000
    <b>Bloomsbury, Dec. 14:</b> Blaeu (Johannes). <i>Vierde Stuck der Aerdrycks-Beschryving, welck vervat Engelandt</i>, i.e. <i>Theatrum Orbis Terrarum</i>. vol 4, England & Wales. £10,500 to £12,500
    <b>Bloomsbury, Dec. 14:</b> Miró (Joan). L'Homme au Balencier, etching, aquatint and carborundum, printed in colours on Japan paper, signed in pencil lower right. £4,000 to £6,000
    <b>Bloomsbury Auctions: Books and Works on Paper, including Fine Photographs. December 14, 2017</b>
    <b>Bloomsbury, Dec. 14:</b> Steve McCurry (b.1950). Afghan Girl, 1984, pigment inkjet print, signed and numbered 48/250 in pencil on lower margin. £2,500 to £3,500
    <b>Bloomsbury, Dec. 14:</b> Keough (Pat and Rosemarie). <i>Antarctica</i>, no 228 of 950 copies, signed by the authors, many colour illustrations, original dark grey morocco. £2,800 to £3,200
    <b>Bloomsbury, Dec. 14:</b> Rowlandson (Thomas). Darby & Joan, the idyllically contended couple sit either side of a stove in a cosy domestic interior, ink and watercolour on wove paper. £1,000 to £1,500
    <b>Bloomsbury Auctions: Books and Works on Paper, including Fine Photographs. December 14, 2017</b>
    <b>Bloomsbury, Dec. 14:</b> Procktor (Patrick). Tiny blue-eyed goldfish, watercolour, 310 x 460mm., signed in blue crayon, lower right, titled and inscribed Muscat Jan 19. £1,000 to £1,500
    <b>Bloomsbury, Dec. 14:</b> Iouri Abramochkin (b.1936). Horsemen, Dagestan, 1968, Lambda print, printed later, signed, dated, editioned 1/8 and annotated in black ink verso. £800 to £1,200
    <b>Bloomsbury, Dec. 14:</b> Ravilious (Eric).- Shakespeare (William). Twelfth NIght, or, What You Will, number 79 of 275 copies , wood-engraved title. £800 to £1,200
    <b>Bloomsbury Auctions: Books and Works on Paper, including Fine Photographs. December 14, 2017</b>
    <b>Bloomsbury, Dec. 14:</b> Michelangelo.- Chastel (André). <i>The Vatican Frescoes of Michelangelo</i>, Photography by Takashi Okamura, 2 vol., one of 600 sets, colour plates. £500 to £700
    <b>Bloomsbury, Dec. 14:</b> Wyndham (John). <i>The Day of the Triffids; The Kraken Wakes; The Chrysalids;</i> together with 8 other volumes. All first editions. £400 to £600
    <b>Bloomsbury, Dec. 14:</b> Alfred Stieglitz (1864-1946). Goats Along The Seine, 1894. Photogravure, printed 1990s by Dorothy Norman, one from an edition of 40 published by Aperture. £400 to £600
  • <b>Christie’s Online, Dec. 5 – Dec. 12:</b> <i>John the Baptist</i>. initial 'H' cut from a choirbook [Lombardy or Siena, c. 1470s]. US$6,000–9,000
    <b>Christie’s Online, Dec. 5 – Dec. 12:</b> <i>Maharaja Ranjit Singh (1780–1839) seated on a terrace with Sikh noblemen</i>. [Punjab, North India, circa 1830-40]. Estimate: US$10,000–15,000
  • <b>Swann Auction Galleries Dec 5:<br>Maps & Atlases, Natural History & Color Plate Books</b>
    <b>Swann Auction Galleries Dec 5:</b><br>John Norman, <i>The American Pilot</i>, complete copy with 11 folding charts, Boston, 1810. $80,000 to $120,000.
    <b>Swann Auction Galleries Dec 5:</b><br>John Smith, <i>New England</i>, London, 1616. $20,000 to $30,000.
    <b>Swann Auction Galleries Dec 5:</b><br>Plancius Petrus, <i>Orbis Terrarum Typus de Integro Multis in Locis Emendatus</i>, Amsterdam, 1594. $10,000 to $15,000.
    <b>Swann Auction Galleries Dec 5:<br>Maps & Atlases, Natural History & Color Plate Books</b>
    <b>Swann Auction Galleries Dec 5:</b><br>Martin Waldseemüller, <i>Tabula Terre Nove</i>, woodcut, Strasbourg, 1513. $30,000 to $40,000.
    <b>Swann Auction Galleries Dec 5:</b><br>Forlani & Zaltieri, <i>Il Disegno del Discoperto della Noua Franza</i>, Venice, 1566. $30,000 to $50,000.
    <b>Swann Auction Galleries Dec 5:</b><br>Richard Hakluyt, <i>Novus Orbis</i>, first appearance of "Virginia" on a printed map, Paris, 1587. $40,000 to $60,000.
    <b>Swann Auction Galleries Dec 5:<br>Maps & Atlases, Natural History & Color Plate Books</b>
    <b>Swann Auction Galleries Dec 5:</b><br>Pieter van den Keere, <i>Nova Totius Terrarum Orbis Geographica</i>, Amsterdam, 1608. $8,000 to $12,000.
    <b>Swann Auction Galleries Dec 5:</b><br>Abraham Ortelius, <i>Theatrum Orbis Terrarum</i>, Antwerp, 1584. $25,000 to $35,000.
    <b>Swann Auction Galleries Dec 5:</b><br>George B. Goode & Samuel A. Kilbourne, <i>Game Fishes of the United States</i>, New York, 1879. $10,000 to $15,000.
    <b>Swann Auction Galleries Dec 5:<br>Maps & Atlases, Natural History & Color Plate Books</b>
    <b>Swann Auction Galleries Dec 5:</b><br>William Faden, <i>The Province of New Jersey</i>, London, 1777. $10,000 to $15,000.
    <b>Swann Auction Galleries Dec 5:</b><br>James Gillray, <i>The Plumb-Pudding in Danger</i>, hand-colored etching, London, 1805. $8,000 to $12,000.
    <b>Swann Auction Galleries Dec 5:</b><br>Pierre Belon, <i>L'Histoire de la Nature des Oyseaux</i>, with woodcut illustrations, Paris, 1555. $8,000 to $12,000.

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