The 2.1-hour presentation and 81-page course book from this September 24, 2007 program by John W. Porter, Esq. provide you with a comprehensive and useful explanation of the current status of IRS attacks on valuation discounts claimed with FLPs and LLCs, the taxpayers’ responses and important cases. Mr. Porter, who is a partner in the Houston, Texas law firm of Baker & Botts, is considered by many to be the leading expert on this subject.

Topics include:

ü Overview

• define bundle of rights

• value thereof

• why IRS attacks entities

• Murphy argument

• gift on formation argument

ü IRC Section 2036(a)(1)

• Bigelow

• Korby

• Strangi

• Thompson

ü IRC Section 2036(a)(2)

• Strangi

• Kimbell

• Cohen

ü Bona Fide Sale For Adequate And Full Consideration

ü Production Of Documents

ü Where Are We Now?

• IRS settlement guidelines

• Lappo, McCord, Peracchio

üDefined Value Or Formula Transfers