There's an important — yet unspoken — phenomenon in the world of estate tax: As the number of estate tax filings has been decreasing nationwide since 2001, there's been a corresponding increase in the Internal Revenue Service's audit coverage rate of estate tax returns. Indeed, at least for the next few years, practitioners should change their assumption from “Federal estate tax returns may be audited,” to “These returns will be audited.” And of course that means all estate-planning attorneys
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