Tax Controversy & Estate Audit Defense for High-Net-Worth Families
Precision. Protection. Postmortem Peace of Mind.
San Diego Roots. Statewide Reach. Elite Representation.
At Stonebridge Litigation, headquartered in the heart of San Diego and La Jolla, we represent Southern California’s high-net-worth individuals, family offices, and fiduciaries in estate, gift, and generation-skipping transfer tax (GSTT) audits and controversies. Whether you are defending a valuation in Encino, preparing exemption allocations in Orange County, or defending the claim of estate tax exclusion in Beverly Hills, our attorneys bring unparalleled discretion and strategic precision to every client relationship.
Specialized Tax Controversy Areas We Handle
- IRS Estate & Gift Tax Audits – Addressing valuation challenges, deduction disputes, and retained interests under IRC §2036 & §2038
- GSTT Audit Defense – Navigating exemption allocations, Form 706GS(D) filings, and skip person compliance
- Advanced Planning Vehicle Review – Defending audits involving GRATs, IDGTs, FLPs, ILITs, and dynasty trusts
- Fiduciary Representation – Protecting trustees, executors, and beneficiaries during scrutiny or inquiry
- Postmortem Planning Support – Including portability elections, disclaimers, and tax-efficient estate resolutions
- Foreign Trust & FBAR Compliance – Audit defense involving offshore assets or reporting requirements
- Valuation Dispute Resolution – Collaborating with credentialed appraisers and estate experts to defend transferred asset values
- Tax Court & IRS Appeals – Sophisticated representation in federal and California forums
Our Estate & GSTT Controversy Services
Audit Defense & Strategy – Responsive representation from first notice to resolution
Tax Court & Appeals – Advocacy in U.S. Tax Court and IRS Independent Office of Appeals
Fiduciary Protection & Guidance – Defending personal liability and supporting prudent compliance
Penalty Abatement – Relief from valuation penalties, reporting lapses, and procedural missteps
State & Federal Filing Assistance – Including Form 706GS(D), 709 gift returns, and FTB correspondence
Strategic Mediation & Settlement – Confidential resolution through IRS Counsel or settlement officers
Serving Southern California from San Diego & La Jolla
Stonebridge Litigation is proudly rooted in San Diego County, with a flagship location in La Jolla, and serving clients all throughout Los Angeles, Orange County, East County of San Diego, Alpine, Pine Valley, Lakeside, and across the state. Our boutique model ensures elevated, tailored representation for every audit, dispute, or fiduciary matter.
FAQ: Estate & GSTT Tax Audit Defense
What makes an estate or gift plan more likely to be audited?
Use of aggressive valuation discounts, transfers involving limited partnerships or GRATs, and high-value foreign assets often trigger IRS scrutiny.
Can I defend challenged exemption allocations for GSTT?
Yes, we analyze allocation strategies, defend return accuracy, and support compliance through Form 706GS(D) filings.
How does IRS define retained interest under §2036?
Retained rights to income, enjoyment, or control may jeopardize estate planning vehicles. We defend transfer integrity and draft appropriate rebuttals.
Who is responsible during estate-related audits?
Executors and trustees may be held personally liable. Our firm protects fiduciaries through direct representation and strategic audit response.
