As an appraiser, we work with estate and gift tax attorneys regularly. Here is some insight from a very recent technical advice given to an estate and gift tax attorney that you and your client should be aware of if you are not already aware of this field service advice.
Lorraine New recently wrote about Field Attorney Advice 20152201F
Lorraine is a former IRS Estate and Gift Tax Attorney and then Manager who practices with George W. Gregory, PLLC, in Troy, Michigan.
She reviewed the facts of the advice, which reviews the facts on how a gift tax return was prepared and concluded that the valuation of the underlying assets coupled with the use of a nickname for the partnership and a disclosed discount was not “adequate disclosure.” Although it has no “precedential” value is bothersome as IRS employees will probably pay attention to it.
You can find her article at Steve Leimberg's Estate Planning Email Newsletter - Archive Message #2342. You can subscribe to the Leimberg Service for ten days for free to try it out at http://www.leimbergservices.com/
About the author
Mike Gregory is a professional speaker, an author, and a mediator. You may contact Mike directly at firstname.lastname@example.org and at (651) 633-5311. Mike has written 12 books (and co-authored two others) including his latest book, The Collaboration Effect: Overcoming Your Conflicts, and The Servant Manager, Business Valuations and the IRS, and Peaceful Resolutions that you may find helpful. [Michael Gregory, ASA, CVA, NSA, MBA, Qualified Mediator with the Minnesota Supreme Court]