IRS offers estate and tax lawyers "tweets," if not guidance on FLP appeals or expert penalties


When is the long-anticipated guidance on Sec. 6695A appraisal/appraiser penalties coming from the IRS? That was among the first questions lobbed to the panel of presenters on tax-related valuation topics at the NACVA conference. “There’s no manual done yet,” reported Sue Kurzweil, a national business valuation issue coordinator with the IRS. “It’s in the works, but I don’t know when the guidelines will be issued,” she said.

A similar question regarding the long-awaited update to the Appeals Settlement Guidelines (ASG) for family limited partnerships didn’t come up during the NACVA sessions, but we’re tracking all important guidance and appraiser initiatives from the IRS. For instance: Last week, the tax service did announce that its Return Preparer Office (RPO) is now on LinkedIn as well as on Facebook and Twitter. “To better communicate with and support the tax professional community,” the RPO will use the social media sites to post the latest changes on competency testing, qualifications, and renewals.

Finally, we did learn from William Cousins III (Meadows Collier Reed Cousins Crouch & Ungerman), the attorney who tried Keller v. United States (S.D. Tex. 2009), that he just argued the appeal in that case to the 5th Circuit in March and a decision is imminent. In the meantime, if you want to review the original Keller decision, in which the federal district court adopted the taxpayer’s roughly 48% in discounts, the case digest and court’s opinion are currently available at BVLaw.


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