Continuing Legal Education

TELESEMINAR: Estate and Gift Tax Audits – A National Perspective

January 29, 2013
12:00 – 1:00 p.m.
1.00 MCLE hours


Every estate and gift tax return is reviewed by hand by IRS personnel and the agency continues to become more aggressive in challenging returns. Being chosen for examination can be a very time-consuming and costly process, putting a premium on understanding the process and preparing for the exam. It also highlights the value of understanding audit triggers and how returns are selected for exam in a bid to avoid audit in the first instance. This program will provide you with a practical guide to estate and gift tax audits, including audit triggers and how to reduce the risk of an exam, preparing for and advocating for a client once their estate is selected for audit, crucial attorney-client, evidentiary and statute of limitation concerns, and much more.


  • Successfully defending estate and gift tax audits
  • Avoiding audit in the first place – understanding audit triggers and how returns are selected for examination
  • Practical guide to the audit process, timeframes, and deadlines
  • Common issues on audit – FLP/FLLCs, defined value clauses, insurance policies and lifetime gifts
  • Documentary preparation for an exam and drafting effective settlement proposals
  • Important attorney-client privilege, statute of limitation, and evidentiary considerations
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Program Speakers:
Keri D. Brown
, Baker Botts, LLP, Texas
Jennifer A. Pratt, Venable, LLP, Maryland


Keri D. Brown is a senior associate in the Houston office of Baker Botts, LLP, where her litigation practice focuses on estate, gift and income tax disputes, including the valuation of business interests and fiduciary controversies.  In her tax controversy practice, Ms. Brown represents clients before the IRS, in Tax Court and in disputes with the US Department of Justice. She also represents fiduciaries of trusts and estates in state courts with respect to administration and fiduciary duty issues.  She also serves as co-vice chair of the Tax Litigation & Controversy Committee of the ABA Real Estate, Trust & Estate Section.  Ms. Brown earned her B.A. from Texas A&M University and her J.D., summa cum laude, from South Texas College of Law.

Jennifer A. Pratt is a partner in the Baltimore office of Venable, LLP, where she has assists client with estate planning, charitable giving, and estate and gift tax controversy matters.  She has extensive experience with estate administration, the preparation of federal estate and gift tax returns, as well as fiduciary income tax returns.  Earlier in her career, she worked with a major national bank and has particular expertise in adapting financial products to the estate planning needs of clients.  He has been named in the 2011 edition of “Maryland Super Lawyers Rising Stars Edition.” Ms. Pratt received he B.A., summa cum laude, from the University of Baltimore, her J.D., magna cum laude, from the University of Baltimore School of Law, and her LL.M. in taxation from the University of Baltimore.