H&A has again successfully settled an estate tax audit. In this case, the IRS confronted the Estate with an additional assessment of nearly $2.4 million dollars in estate taxes. The IRS assessment was based largely on three issues. First, the IRS argued that an LLC created prior to death should be included in the estate under IRC Section 2036. Second, the IRS argued that a vacation home previously owned by a QPRT and rented back to the decedent should be included in the decedent’s taxable estate under IRC Section 2036. Finally, the IRS disallowed an estate tax deduction for interest on a Graegin loan taken from the recently created LLC to pay estate taxes.
H&A was able to successfully defend the Estate on each and every issue on which the IRS based its assessment. Through proper planning, creative thinking, and hard work by H&A, the Estate recently received from the IRS a no-change closing letter. This was a collaborative effort across all firm departments, and is a testament to the wide ranging skills and knowledge offered to our clients. I’d like to thank everyone involved for their efforts in bringing this matter to a successful conclusion.
We cannot guaranty similar results, as success or failure of any audit defense depends on the facts and circumstances of the individual case. If you need help dealing with the IRS, please do not hesitate to contact us at (404) 255-7400.