Report from the Front: Defending DiscountsReport from the Front: Defending Discounts
There's some good news in the ongoing war with the Internal Revenue Service over family limited partnership (FLP) discounts: IRS agents are settling practically all of the cases and even most of the ones. That means it pays to know how to negotiate during the estate and gift tax audit stage. It also means you have to understand what's happening on the ground. Audits have long been a good percentage
Joseph F. McDonald, III and Amy K. Kanyuk, partners, McDonald & Kanyuk, PLLC, Concord, N.H.
There's some good news in the ongoing war with the Internal Revenue Service over family limited partnership (FLP) discounts: IRS agents are settling practically all of the “good” cases — and even most of the “bad” ones. That means it pays to know how to negotiate during the estate and gift tax audit stage. It also means you have to understand what's happening on the ground. Audits have long been a good percentage of our practice, so we offer here the benefit of our perspective and experience.1
The IRS begins fighting discounts during the field audit. FLP cases are identified and submitted to the Office of Appeals for national coordination. There are...
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