Tax Controversy & Estate Audit Defense for High-Net-Worth Families
At Stonebridge Litigation, headquartered in the heart of 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
