Choate Hall & Stewart reports that for estates that file estate tax returns, it is a virtual certainty that such returns will be audited. The article begins as follows:
The substantial federal estate tax exemption ($5.34 million) available under current law provides welcome estate tax relief to the wealthy. One predictable outcome associated with this higher exemption amount is that fewer and fewer federal estate tax returns are being filed each year. Unfortunately, however, those estate tax returns that are filed are subject to greater IRS scrutiny than ever before.