Brooklyn Law's Bradley Borden has a good summary here. The punchline:
"Owners of art and collectibles should ... be concerned, however, because many such transactions may not satisfy the technical requirements of the tax law. Owners of art and collectibles must tread carefully when claiming tax-free treatment on the transfer of such property. The law governing tax-free exchanges of art and collectibles is a veritable minefield, and the slightest foot-fault with such transactions could result in significant amounts of tax."
For a longer version from Borden, see here.
For a recent discussion of the issue, see here.
