Keri D. Brown


Keri Brown


P: +1.713.229.1436
F: +1.713.229.2736
  • Steinberg – Tax Court rejected IRS challenge to gift tax value offset for donees’ assumption of potential estate tax under I.R.C. § 2035 ("net, net gift") (Steinberg v. Comm’r, 141 T.C. 258 (2013))
  • Estate of Anne Y. Petter – successful defense of taxpayer in case of first impression involving gift/sale of LLC units to family and charity using a dollar value formula based on values as “finally determined for federal gift tax purposes.” (Petter v. Comm’r, 98 T.C.M. (CCH) 534 (2009)), aff’d, 653 F.3d 1012 (9th Cir. 2011))
  • Hendrix – successful defense of taxpayer in case regarding the tax effect of a gift of corporate stock made by way of a dollar-based defined value formula (Hendrix v. Comm’r, T.C. Memo 2011-133 (June 15, 2011))
  • Estate of Helen Christiansen – successful Eighth Circuit affirmance of Tax Court decision in case of first impression regarding tax effect of partial disclaimer of limited partnership interest to charity made by way of formula based on values “as finally determined for estate tax purposes.” (Estate of Christiansen v. Comm’r, 586 F.3d 1061 (8th Cir. 2009))
  • Estate of Charles H. Murphy, Jr. – successful $42 million estate tax refund suit involving numerous valuation issues and IRS attempt to ignore limited partnership under I.R.C. § 2036. (Estate of Murphy v. United States, No. 07-CV-1013, 2009 WL 3366099 (W.D. Ark. Oct. 2, 2009))