Nebraska Activity #121268, 1.0 hour CLE
Every estate and gift tax return is reviewed by hand by IRS personnel and the agency continues to be assertive in challenging returns it believes have overstated valuation discounts or takes other positions that can be challenged. When a client return is chosen for examination and audit, an estate is subject to a very time-consuming and costly process. Understanding the steps in the process, the personnel involved, and the limits of what you can reasonable expect as part of a settlement are all essential to successfully concluding an audit for your client. It’s also very important to understand audit triggers and how returns are selected for exam in an effort to avoid audit in the first instance. This program will provide you with a practical guide to estate and gift tax audits, including audit triggers and how to reduce the risk of an exam, preparing for and advocating for a client once their estate is selected for audit, crucial attorney-client, evidentiary and statute of limitation concerns, and much more.
- Framework of estate and gift tax audits – and how to successfully conclude for a client
- Timeline, process, personnel and deadlines – understanding how an audit unfolds
- Avoiding audit in the first place – common audit triggers and how returns are selected for examination
- Review of common issues on audit – FLP/FLLCs, defined value clauses, insurance policies and lifetime gifts
- Practical guidance on drafting responses and working with IRS personnel
- Determining the range of reasonable settlement proposals
- Important attorney-client privilege, statute of limitation, and evidentiary considerations
Keri D. Brown is a partner in the Houston office of Baker Botts, LLP, where her litigation practice focuses on estate, gift and income tax disputes, including the valuation of business interests and fiduciary controversies. In her tax controversy practice, Ms. Brown represents clients before the IRS, in Tax Court and in disputes with the US Department of Justice. She also represents fiduciaries of trusts and estates in state courts with respect to administration and fiduciary duty issues. She also serves as co-vice chair of the Tax Litigation & Controversy Committee of the ABA Real Estate, Trust & Estate Section. Ms. Brown earned her B.A. from Texas A&M University and her J.D., summa cum laude, from South Texas College of Law.
Jennifer A. Pratt is a partner in the Baltimore office of Venable, LLP, where she has assists client with estate planning, charitable giving, and estate and gift tax controversy matters. She has extensive experience with estate administration, the preparation of federal estate and gift tax returns, as well as fiduciary income tax returns. Earlier in her career, she worked with a major national bank and has particular expertise in adapting financial products to the estate planning needs of clients. She has been named in the 2011 edition of “Maryland Super Lawyers Rising Stars Edition.” Ms. Pratt received he B.A., summa cum laude, from the University of Baltimore, her J.D., magna cum laude, from the University of Baltimore School of Law, and her LL.M. in taxation from the University of Baltimore.
To Register:Cost $89.00
If you need additional information on your CLE credits please contact:
- Click on abo9ve link
- Click “Login to add to cart” button at the bottom of the program page
- This will take you to the log in page, FIRST time users will need to create a user name and password that is separate and distinct from any information you may have used for the Nebraska State Bar website
- Please be sure to use the attorney name and contact information of the person who is to receive the CLE credit
- Once completed click “Update & Proceed to Payment”
- The final step is to click “Submit Payment”
- At this point you will receive an email confirmation of the purchase
- The day before the Program you will receive the dial in information and program materials
- We will submit the program participation information to the Nebraska State Bar Association within 48 hours of the program completion
Sara Weber, Nebraska State Bar Association
(402) 475-7091 ext # 131; email@example.com