Experience
  • General Experience
    • Administration of numerous estates that required the filing of estate tax returns

      Handling the administration of numerous estates that required the filing of estate tax returns, including estates that involved the credit for tax on prior transfers, a qualified domestic trust for a non-U.S. citizen surviving spouse, and family limited partnerships.

      Advising clients on use of trusts designed to save gift and estate taxes

      Advising a number of clients on the use of "zeroed-out" grantor retained annuity trusts designed to take advantage of low interest rates and transfer assets to children without the imposition of gift taxes, as well as intentionally defective grantor trusts and generation-skipping transfer (GST) trusts.

      Defense of client in tax-free split in family-held businesses

      Defended client in tax-free split of $1.5 billion in family-held businesses with substantial real estate holdings and ownership of NFL franchise. The case spawned three lawsuits and involved many consultants in areas of accounting, tax planning and estate planning.

      Drafting of various trusts and estate documents

      Drafting many simple and complex wills and trusts, revocable trusts, charitable remainder trusts, charitable lead trusts, grantor retained annuity trusts, grantor retained unitrusts, qualified personal residence trusts, and numerous other tax-driven instruments.

      Estate Administration

      Representing administrators and executors in the administration and probate process including probate of wills, estate and probate litigation matters and preparation of federal estate and state inheritance tax returns.

      Estate Planning

      Drafting wills, trusts (including charitable trusts, grantor trusts, asset protection trusts, and personal residence trusts), powers of attorney, advanced health care directives, and living wills.

      Formation of family limited partnerships and LLCs

      The preparation of family limited partnerships and limited liability companies, using the laws of the State of Alabama, Georgia, Delaware, South Dakota, and Alaska.

      IRS audits and Tax Court litigation matters

      Numerous IRS audits and Tax Court litigation matters involving estates ranging from $1 million to $200 million.

      Pre-marital Agreements

      The preparation of numerous pre-marital agreements.

      Preparation of estate and gift tax returns

      Preparation of numerous estate and gift tax returns involving transfers ranging from $1 million to in excess of $200 million

      Preparation of IRS private letter ruling requests

      Preparation of numerous private letter ruling requests to the Internal Revenue Service involving various gift, estate and generation-skipping tax issues.

      Preparation of tax-oriented wills, trusts and business entities

      Representation of families on a routine basis in preparation of appropriate tax-oriented Wills, Trusts, and family business entities.

      Probate Court Litigation

      Probate Court litigation in over 40 contested matters involving wills, trusts, conservatorships, and probate matters

      Representation of beneficiaries in intra-family dispute

      Representing three beneficiaries of trusts created by their grandfather in an intra-family dispute, successfully causing the trustee to resign and recovering assets on behalf of the trusts.

      Representation of Executors

      Representation of Executors in handling the administration of estates and dealing with the IRS in estate and gift tax audits and litigation.

      Trusts

      Rhone v. Adams, 986 So. 2d 374 (Ala. 2007)

      Dismissal of putative class action against trustees of charitable trust based on absence of standing affirmed.

      Neal v. Neal, 856 So. 2d 766 (Ala. 2002)

      Summary judgment upholding settlement of dispute involving construction and management of trust affirmed.