Timely filing of a properly prepared gift tax return will begin the statute of limitations period for revaluing the gift for gift tax purposes, but not necessarily for estate tax purposes. Walsh describes how the Taxpayer Relief Act of 1997 (TRA'97) can provide a taxpayer with potential solutions and describes how the final regulations provide planning opportunities for attorneys to assist their clients.
Walsh, Daniel J.
"Gift Tax Returns as a Planning Strategy,"
Marquette Elder's Advisor:
3, Article 12.
Available at: http://scholarship.law.marquette.edu/elders/vol2/iss3/12