14 February 2019 - Article
Successfully defended an individual in a gift tax audit in which the IRS challenged the valuations of several real properties and business entities, saving the individual approximately $1,500,000 in gift tax.
Drafted Delaware and South Dakota irrevocable trusts for an individual who wished to be an anonymous benefactor.
Prepared petition requesting Section 9100 relief, which the IRS granted in a private letter ruling (PLR). As a result, a surviving spouse was granted an extension of time to elect to treat a qualified terminable interest property (QTIP) trust as two separate trusts, saving the surviving spouse approximately $3,000,000 in GST taxes.
Drafted a declaration to support a bankruptcy trustee’s right to recover the debtors’ personal residence, which debtors had fraudulently transferred to two qualified personal residence trusts (QPRTs).
As an IRS attorney, represented the federal government’s interests in the examination of federal estate tax and federal gift tax returns; examined estate plans that included special use valuation, family limited partnerships (FLPs), Graegin loans, private split dollar life insurance, sales to intentionally defective grantor trusts (IDGTs) in exchange for promissory notes, and self-cancelling installment notes (SCINs).
‘Animal Capital,’ Family Capital - February 27, 2019, quoted
Estate and Gift Tax Return Preparation and Audit Tips, Estate Planning Journal (WG&L), Volume 44, Number 9, September 2017
Daily Report for Executives, Bloomberg BNA - May 26, 2017, quoted
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Beverly Hills Bar Association, Trusts & Estates Section
ProVisors, West Hollywood, Women, and Los Angeles Estate and Succession Planning Groups
Inside the Minds of Estate Planning Attorneys, Wells Fargo The Private Bank, April 17, 2019
Preparing Gift and Estate Tax Returns and the Audit Process, JH Advanced Markets Web Portal, April 13, 2018
Estate and Gift Tax Return Preparation and Audit Tips, Beverly Hills Bar Association, February 20, 2018
Taxation and Representation: Career Paths in Tax Law, University of California Los Angeles, February 6, 2018
Dodging Bullets and Navigating Minefields, Helpful Tips for Preparing Estate and Gift Tax Returns and Resolving Audits from Two Former IRS Attorneys, USC Tax Institute, January 25, 2017
Estate Planning: Looking at Our World Through Income Tax Glasses, CalCPA, Westside Discussion Group, December 20, 2016
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Estate and Gift Tax Returns: Common Mistakes and How to Fix Them, ProVisors Los Angeles Estate and Succession Planning Affinity Group, February 11, 2016
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Estate Planning: Looking at Our World Through Income Tax Glasses, ProVisors Los Angeles Estate and Succession Planning Affinity Group, October 8, 2015
Introduction to the Federal Gift Tax, Internal Revenue Service, September 2012
Introduction to the Federal Estate Tax, Internal Revenue Service, September 2012