EST2521. A View from the Front Lines – Current Issues in Estate Tax Audits and Litigation

Join tax litigator Keri Brown for a discussion of hot topics that the IRS is focusing on in their transfer tax audits and litigation. We’ll focus on current issues and trends at the audit level, appeals, and in litigation, including the IRS’s current darlings (formula clauses, split-dollar life insurance, QTIP terminations, penalties), as well as the old standbys (section 2036, valuation, adequate disclosure), and more. We will discuss recent cases (including McDougall and Estate of Anenberg), the IRS’s positions, and how to best position our clients at the planning level. Come for the CLE; stay for the fun!

Learning Objectives:

• Understand the IRS's developing focus areas
• Understand how to position your client for audit success at the planning level, including how to minimize the effect of a privilege waiver