Engaged to provide advice regarding transfer of majority interest in closely held business to children of founder.  Net value of client’s estate in excess of $15,000,000.  Owners of business include Client, client’s first wife, client’s second (current) wife, four adult children, two of whom are actively involved in the conduct of the business, and a number of unrelated (non-family) owners.  Result:  Implementation of combination of estate tax planning strategies anticipated to result in:  (a) stream of income to Client for life, (b) reduction of estate taxes payable upon Client’s death from in excess of $5,675,000 to under $350,000 if death occurs prior to July 2, 2013 or under $42,500 if death occurs after July 1, 2013, (c) deferral of up to $2,260,000 in estate taxes until death of current spouse which children will be able to pay with proceeds of life insurance on her death and (d) assurance that Client’s interests in business will pass to four children upon his death and the death of his current wife.

Upon the death of Client’s mother, engaged to provide advice regarding the post-mortem trust administration of parents living trust and minimization of federal estate tax liability in excess of $2,000,000 anticipated to be incurred upon death of father.  Result:  Federal estate taxes paid upon father’s death the following year:  $59,431.

After auditing client’s income tax return filed for 2005, Franchise Tax Board assessed an “accuracy related penalty” and interest in excess of $40,000.  Represented Client in protest of imposition of this penalty.  Result:  Penalty fully abated.