The lover never sees personal resemblances in his mistress to her kindred or to others. His friends find in her a likeness to hermother, or her sisters, or to persons not of her blood. The lover sees no resemblance except to summer evenings and diamond mornings, to rainbows and the song of birds.
The question if this is a work of art or not is not very interesting for us. Probably it is situated in between the established categories. Anyway the audience which is interested in art would be the most open-minded and willing to think about it.