Estate and gift tax dispute resolution is the process of defending executors, trustees, and beneficiaries against IRS examinations of Form 706 (estate tax) and Form 709 (gift tax) returns — including valuation challenges, family limited partnership (FLP) discount disputes, and undervaluation penalties. With the federal estate tax exemption currently at $13.61 million per individual but set to decrease significantly after 2025, the IRS is aggressively auditing high-value estates and lifetime gift transfers. Neil Jesani Tax Resolution's team of tax professionals and CPAs specializes in estate and gift tax defense, representing executors and trustees through audits, IRS Appeals , and the formal dispute process to protect family wealth and minimize tax exposure. Why Does the IRS Audit Estate and Gift Tax Returns? The IRS audits estate and gift tax returns at a significantly higher rate than individual income tax returns because the revenue at stake in a single estate tax case can be enormous — often millions of dollars in a single assessment. The IRS Estate and Gift Tax examination group focuses on returns reporting gross estates above $5 million, with particular scrutiny directed at returns claiming significant valuation discounts, charitable deductions, or complex asset structures such as family limited partnerships and LLCs. The IRS has invested heavily in training specialized estate tax examiners and developing sophisticated valuation tools. These examiners work closely with IRS engineers and appraisers to challenge taxpayer valuations of real estate, closely held businesses, art, collectibles, and other hard-to-value assets. Understanding why the IRS selects certain returns for audit helps executors and trustees prepare proactive defense strategies that address likely areas of IRS scrutiny before the examination even begins. Under IRC Section 2031, the gross estate includes the fair market value of all property in which the decedent had an interest at the time of death. The...