EST2614. A View from the Front Lines – Current Issues in Estate and Gift 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. This session examines current audit, appeals, and litigation trends, including the IRS’s recent focus areas, such as formula clauses, split‑dollar life insurance, QTIP terminations, and penalties. Longstanding issues like section 2036, valuation, and adequate disclosure will be discussed. Recent cases, including Elcan and McDougall, analyze the IRS’s positions, and discuss strategies for effectively positioning clients at the planning stage will be reviewed.

Learning Objectives:

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