EST2416. A View from the Front Lines – Current Issues in Estate Tax Audits and Litigation

IRS audits of estate and gift tax returns are on the rise. This discussion will address current issues and trends in the transfer tax controversy arena at the audit level, appeals, and in litigation, including the valuation and transfer of interests in closely-held entities, the use of formula clauses, adequate disclosure of lifetime transfers, and split-dollar life insurance. The discussion will include recent caselaw, positions taken by the IRS, and ways to address both at the planning level.

Learning Objectives:

• Identify issues currently being raised by the IRS in estate and gift tax audits.
• Identify strategies for preemptively addressing these issues at the estate planning level.