Segal, Cohen & Landis, P.C.

IRS Estate Tax Audit Defense and Dispute Resolution

IRS tax attorneys — Beverly Hills, CA. National representation.

Estate documents in a leather folio beside house keys — stewardship of what's passed on

33+ Years IRS Experience

U.S. Tax Court Admitted

Federal estate tax applies to estates exceeding the applicable exclusion amount — $13.61 million per individual in 2024. IRS estate tax audits are disproportionately common. The IRS scrutinizes valuations of closely held businesses, real estate, and other hard-to-value assets. Deductions for family limited partnerships, charitable bequests, and marital deductions are examined closely.

At Segal, Cohen & Landis, we represent executors, personal representatives, and heirs in IRS estate tax examinations, valuation disputes, and estate tax litigation.

How We Help

Our Approach to Estate Tax Attorney

Estate Tax Audit Representation

We represent executors before IRS Estate and Gift Tax specialists. We control document production, present supporting valuations, and defend the estate's reported positions.

Valuation Disputes

Business valuation disputes are the most contested issue in estate tax audits. We retain and coordinate qualified appraisers, challenge the IRS's valuation methodologies, and present a legally defensible valuation supported by market data and expert opinion.

Estate Tax Return Preparation (Form 706)

Form 706 is one of the most complex tax forms in existence. We prepare accurate estate tax returns, identify all available deductions and elections (QTIP, portability, special use valuation), and minimize taxable estate values within the law.

Estate Tax Litigation

When IRS estate tax adjustments are incorrect and cannot be resolved administratively, we litigate in U.S. Tax Court.

How It Works

The Resolution Process

Estate Tax Return Review

We review the filed or proposed Form 706, identify potential IRS challenges, and assess the estate's overall exposure.

Valuation Support

We coordinate with qualified appraisers to support all hard-to-value assets before the IRS asks for them.

Audit Representation

We handle all IRS communication, document requests, and audit conferences.

Appeals or Litigation

If the IRS proposes unacceptable adjustments, we appeal to the IRS Office of Appeals or petition Tax Court.

Ready to Resolve Your Tax Problem?

Our attorneys have helped thousands of clients resolve IRS matters. Your consultation is free and confidential.

Schedule a Free Consultation Call (310) 285-3999

Common Questions

Frequently Asked Questions

Who has to file a federal estate tax return?+

Estates of US citizens and residents with gross assets and prior taxable gifts exceeding $13.61 million (2024, indexed for inflation) must file Form 706.

What is portability?+

Portability allows a surviving spouse to use any unused estate tax exclusion from the deceased spouse's estate. An estate tax return must be filed to elect portability — even if no estate tax is owed. Missing this election can cost millions in estate tax for the surviving spouse's estate.