DESCRIPTION
Defending Estate and Gift Tax Audits
The IRS reviews every estate and gift tax return and audits them at a far higher rates than income tax returns. 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 reasonably expect as part of a settlement are all essential to successfully concluding an audit. It’s also very important to understand how returns are selected for exam. This program will provide you with a practical guide preparing for and defending and audit and tips for reducing the risk of triggering an audit.
- Timeline, process, personnel and deadlines – understanding how an audit unfolds
- 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
- Drafting responses and working with IRS personnel
- Determining the range of reasonable settlement proposals
- Important attorney-client privilege, statute of limitation, and evidentiary considerations
Speakers:
Brian R. Harris is a partner in the Tampa, Florida office of Fogarty Mueller Harris, PLLC, where he represents clients in federal, state, and local tax controversy and litigation throughout the United States. He also represents clients before the IRS, state departments of revenue, and municipalities. Earlier in his career, he was a trial attorney with the U.S. Department of Justice, Tax Division, and lead attorney for the United States and IRS in federal courts across the country. Mr. Harris received his B.S. and M.S. from the University of Florida and his J.D. from the University of Florida College of Law.
Disclaimer: All views or opinions expressed by any presenter during the course of this CLE is that of the presenter alone and not an opinion of the Oklahoma Bar Association, the employers, or affiliates of the presenters unless specifically stated. Additionally, any materials, including the legal research, are the product of the individual contributor, not the Oklahoma Bar Association. The Oklahoma Bar Association makes no warranty, express or implied, relating to the accuracy or content of these materials.