We defend our estate and tax planning for clients in the event of an audit, and we have successfully negotiated settlements with the IRS on gift/estate tax audits. Examples of settlement successes include:
• Recognition of family owned LLCs for gift purposes.
• A 22.5 percent discount for partial interests in real property.
• A 20 percent combined discount for a marketable securities LLC.
• A full estate tax deduction for interest on Graegin notes.
• A 35 percent combined discount for a marketable securities limited partnership.
• Having defined value formulas in gifts and sales respected by the IRS.
Experience
