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Defending Estate and Gift Tax Audits

Total Credits: 1 including 1 CLE

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Probate & Estate Planning
Brian R. Harris
Original Program Date:
May 02, 2024
Never expires.


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



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Fogarty Mueller Harris PLLC

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.