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Estate Gift Tax Return

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In 1998 I filed an Estate Gift Tax return for 1997.
I based my gifts on recommendations of an attorney. He formed a Limited Liability Partnership and funded the partnership with commercial real estate. He had the property appraised and then had an re-appraisal performed and under the IRS rules, discounted the value due to it being a restricted partnership which would cause the value of a Unit to be less than the original appraised value. The IRS has refused the re-evaluation and is asking me to pay Estate Taxes on the amount that exceeds my lifetime credits. My intentions were to Gift to My Children and Grandchildren only the amount that I was authorized to transfer without oweing Estate Taxes. My question is: Can I go back and file an amended return for 1997 to correct this problem>????
 



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