Estate and Gift Tax Controversies
- Representation of the estate of the majority owner of a large Midwestern agri-business before the Internal Revenue Service's Appeals Division, resulting in a favorable administrative decision saving the estate more than $350,000 in transfer taxes.
- Representation of taxpayers in a successful appeal of IRS' gift tax assessment resulting from our clients' gift of a minority stock interest in a publicly-traded life sciences company to a family limited partnership incident to a recapitalization of the public company's equity structure. After submission of the taxpayers' briefs, the IRS withdrew its deficiency assessment of more than $500,000 in transfer tax liability.
- Representation of second generation shareholders of a large Midwestern manufacturing company in a successful private letter ruling. The ruling involved the income, gift and generation-skipping tax consequences of litigation over the proper construction and severance into separate shares of a multi-generational trust owning more than $300 million worth of the company's stock.
- Representation of the estate of the majority owner of an Iowa-based bank holding company in IRS' audit proceedings, and subsequent sale of the estate's stock holdings to an employee stock ownership trust ("ESOT").
- Representation of two minority shareholders in overturning a $1 million gift tax deficiency assessment in a proceeding before the Internal Revenue Service's Appellate Division.
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