The Internal Revenue Code imposes a substantial tax on annual gifts and the fair market value of the assets includible in the decedent’s gross estate. Most estate and gift tax audits involve complex valuation issues. Valuation, while often considered a simple matter, is a complex decision making process. A proper valuation analysis requires a thorough understanding of the taxpayer’s ownership property rights in a closely held business.
A tax controversy attorney, working with a skilled appraiser, may be able to successfully argue that the fair market value of the property rights should be reduced, and thereby reducing the federal estate tax or gift tax liability.