The IRS has issued final regulations on the procedure a taxpayer must go through in order to contest an IRS determination of a gift's value in Tax Court. In order to be eligible for such a declaratory judgment, the Tax Court must determine if the taxpayer had exhausted all other administrative avenues.
See Tax Analysts: "IRS Issues Final Regs on Disputing Gift Valuation Determination in Tax Court," 2009 TNT 172-43, September 8, 2009.
Posted by Raj Chudgar, Associate Editor, Wealth Strategies Journal

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