[EstGift] Annual Meeting Material and Agenda

[Mickey Davis]

I'm looking forward to seeing everyone in Tucson! The Estate and Gift Tax Committee will meet on Wednesday, March 5th from 3:00 to 6:00 pm.

The materials for the meeting can be found on the private side of the web site:
http://www.actec.org/private/ACTECAnnual2014/EstGift/Estate-and-Gift-Tax-Committee-Annual-2014-Materials.pdf

Special thanks to Jonathan Blattmachr, Turney Berry, Jerry Levine, Carlyn McCaffrey, Charlie Nash, Eric Viehman, Stephanie Loomis-Price and David Pratt for their willingness to share their thoughts.  I am still looking for a volunteer to take minutes!

The agenda is copied below:


3:00-3:10

Welcome; Approval of Minutes; Housekeeping


3:10-3:40


Trombetta vs. Comm'r, T.C. Memo. 2013-234: Taxpayer's lifetime transfers of real property to two trusts held to be transfers with retained interest, and therefore includible in gross estate. Jonathan Blattmachr


3:40-4:00


Kite v. Comm'r (Rule 155 Order and Decision, Cause No. 6772-08, unpublished): Interpreting Section 2519 to mean that full amount of deemed transfer of QTIP trust remainder interest is gift, without offset for consideration received by surviving spouse. Turney Berry


4:00-4:20

Estate of Tanenblatt v. Comm'r, T.C. Memo. 2013-263: Taxpayer's characterization of transferred interests as assignee interests disallowed and IRS's valuation upheld; Estate of Helen A. Richmond v. Comm'r, T.C. Memo 2014-26: Taxpayer's and IRS's capitalization-of-earnings and built-in gain valuation methodology reject and court's methodology substituted-valuation penalties imposed. Jerry Levine on behalf of the FLP/FLLC Valuation Subcommittee


4:20-4:40


Estates of Woelbing v. Comm'r,   Docket Nos. 30261-13 and 30260-13, United States Tax Court:  IRS challenge of sale to IDGT transactions for both gift and estate tax purposes.  Carlyn McCaffrey


4:40-5:00


Sharp v. Comm'r, TC Memo 2013-290; Estate of Helen A. Richmond v. Comm'r, T.C. Memo 2014-26: Suggestions for steps advisors can take in proving reasonable cause to avoid accuracy-related penalties. Charlie Nash on behalf of the 706/709 Reporting/Audits/Pymts/Deferral/

Penalties Subcommittee


5:00-5:40


Open Forum:  Has your client "script" changed in view of portability and high exemptions? Where are your conversations taking you and your clients? - Led by Eric Viehman


5:40-5:50


IRS Settlement Survey.  Stephanie Loomis-Price and David Pratt


5:50-6:00


Rev. Proc. 2014-18, 2014-7 IRB 513-Extension of time to file portability returns. - Led by Mickey R. Davis


6:00


Adjourn



Safe Travels,

Mickey R. Davis
Davis & Willms, PLLC
Fellow, American College of Trust and Estate Counsel
Board Certified - Estate Planning & Probate Law Texas Board of Legal Specialization
3555 Timmons Lane, Suite 1250
Houston, Texas 77027
(281) 786-4502 voice
(281) 742-2600 fax
mickey at daviswillms.com<mailto:mickey at daviswillms.com>   |   www.daviswillms.com<http://www.daviswillms.com/>
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