Report No. 12 (Thu. 1/17)
As we have done in January for the last eleven years, and again with the
permission of the University of Miami School of Law Center for Continuing
Legal Education, we will be posting daily Reports to this list containing
highlights of the proceedings of the 42nd Annual Philip E. Heckerling
Institute on Estate Planning that is being held January 14-18, 2008 at the
Orlando World Center Marriott Resort and Convention Center in Orlando,
Florida, a new venue for the Institute starting in 2007. A complete listing
of the proceedings will be published here and is also available on the
Institute's Web site at http://www.law.miami.edu/heckerling.
We also will be posting the full text of each of these Reports on the ABA
RPPT Section's Web site, as we have since the 2000 Institute. Those Reports
can be found at URL http://www.abanet.org/rppt/meetings_cle/heckerling. In
addition, each Report can also be accessed at any time from the ABA-PTL
Discussion List's Web-based Archive at URL
http://mail.abanet.org/archives/aba-ptl.html.
===========================================================
This Report covers A PRACTICAL GUIDE TO TAX PREPARATION IN LIGHT OF NEW IRS
RULINGS AND REGS, Trust Investment Law, Portfolio Allocation, and Total
Return Damages, INDIVIDUAL TRUSTEES AND DISCRETIONARY TRUSTS, and Section
453, OID, Earnouts, Holdbacks, Price Reductions, Escrows & Other Contingent
Payments from the Thursday Special Sessions. In addition, the LISI
Newsletter entitled "Knight Court Heard From - 2% Sitcom Renewed for at
Least One More Season (of Regulations)" is reproduced in full at the
end. We anticipate that the next Report will cover more of the Thursday
sessions and the Wednesday ever popular Q&A session.
===================================================================
SPECIAL SESSION III-B - A PRACTICAL GUIDE TO TAX PREPARATION IN LIGHT OF
NEW IRS RULINGS AND REGS
Thursday, January 17, 2008
Presenters: Ann Burns and Gray Mooty plus Catherine Hughes, U.S. Dept of
Treasury
Reporter: Carol Sobczak
This is a continuation of Ms. Burns' talk about the Proposed
Regs under section 2053. Unlike the title, it did not present any issues
except the new proposed regs (other than informing everyone about the
Supreme Court's decision in the Knight case, which if you are a part of
this listserve, you probably are aware). If you have not been reading your
e-mail, except for this one, the Supreme Court ruled (9-0) that the 2%
floor for investor service fees incurred by a trustee applies.
Ms. Hughes (of the IRS) does not believe that this "closes the
door" on the issue, but rather believes future issues will be ruled upon on
a case-by-case basis.
She also warned us to read the proposed regs on the taxpayer
preparer penalties and to comment on same. Even if we believe they may not
apply to the estates and trust area, don't wait until the final regs are
issued (like with Circular 230), because they may apply to us and if we do
not comment now, we may be stuck with them when finalized.
Why were the 2053 proposed regs promulgated? Because of the
different treatment in the circuits, and the IRS believes that similarly
situated taxpayers should be treated the same. Ms. Hughes also noted the
IRS view that the valuation of assets is NOT the same as the valuation of
claims. But she warned us not to rely on anything she said,
The presentation materials presented seven problems re: the
proposed regs under section 2053. Some of the more important issues that
arose from this presentation include the following.
The proposed regs are not effective until the final regs are
issued. HOWEVER, Ms. Hughes reminded us that they reflect the current IRS
view. So be careful in filing current returns, because you don't know what
position the IRS may take, and it may depend upon your jurisdiction.
The first problem concerned the guarantee by a decedent of a
family debt. Remember that gratuitous promises are NOT deductible. Also,
the proposed regs only allow a taxpayer to deduct claims that are ACTUALLY
paid. If the claim is paid in installments, taxpayer must file a
protective claim for refund (form 843) every time a payment is made. Ms.
Hughes did not believe this would cause undue burdens for the taxpayer and
NO MENTION WAS MADE OF THESE ADDITIONAL BURDENS. A saving grace is that
attorney fees (and other expensed) incurred in defending or litigating the
claim are also deductible. Query, when does the taxpayer file the
protective election form? Every month when attorney fees paid? Panelists
said yes, OR at some reasonable time.
There is no guidance on what the statute of limitations is on
making a "final" claim for refund, so we are still in the dark about when
we can do so. And the protective election must be filed before that
statute expires. What if the claims are paid over time? No answers given.
In problem 2, the issue was a claim for services rendered before
death. First, claims by family members will be presumed to be
invalid. Second, the claim must be enforceable under state law.
Problem 3 concerned spousal settlements arising under divorce
decrees. Again, no deduction can be claimed until the claim is actually
paid. Also, if you have a contingent recurring obligation, you can only
deduct AS PAID. (Ed. comment: Does that mean estates will need to be kept
open for years and years?????)
If you file a FET return and then realize you undervalued an
asset, there is no obligation to file an amended return. HOWEVER, the
proposed regs require you to notify the Commissioner if you took a
deduction for a claim and it was not ever paid. (Ed. comment: During what
time period? Who will know? In addition, WHEN WILL THE EXECUTOR BE
RELIEVED OF LIABILITY? No answers were given.)
The other problems were similar. Taxpayers have the burden of
proof if they want to take a deduction for more than their share of a claim
in jointly-owned property. Taxes cannot be deducted until actually paid
(therefore, in EVERY estate of mine in CA where a client owns real
property, I will have to file a protective claim for refund). Finally, the
biggest complaint the IRS has received so far is as follows:
If my estate has a claim against a third party for $1 million,
estate must include a $1 million asset on 706. BUT, if it has a
counterclaim for $600,000 which is contingent, nothing may be deducted.
Does anyone but me think this is going to put tons of money in
the treasury and out of the hands of our client? Just one more reason for
them to distrust us?
====================================================
Special Session 3-F - Trust Investment Law, Portfolio Allocation, and Total
Return Damages: The Role of Empirical Analysis
Thursday, January 17, 2008
Presenters: Robert Sitkoff and Max Schanzenbach
Reporter: Joanne Hindel
As a follow-up to Rob Sitkoff's session in the morning entitled:
"Perpetuities, Taxes, and Asset Protection: An Empirical Assessment of the
Jurisdictional Competition for Trust Funds", Rob and Max indicated that the
purpose of this session was to demonstrate how real-world data on trust
investment allocations can be used to assess breach and determine damages
under the new prudent trust investment laws.
Rob S. first described the data that they used in their empirical analysis.
The trust data (state-level panel data) come from annual reports collected
by the four federal agencies charged with banking regulation: (1) the
Federal Deposit Insurance Corporation (FDIC); (2) the Federal Reserve
System; (3) the Office of Thrift Supervision (which superseded the Federal
Home Loan Bank Board); and (4) the Office of the
Comptroller of the Currency. All banks and other financial institutions
that are regulated by these agencies must file annual reports detailing
their trust holdings, including
total assets and number of accounts. Based on this data, from 1968 until
2001 the Federal Financial Institutions Research Council published annual
reports of trust holdings by regulated entities, summarizing the results by
state. Since 2001, the FDIC has been publishing these reports (now
available online) organized by individual institution and by state.
Rob S. took the audience through a brief history of trust investment law
in the United States starting with the adoption of the legal list rule that
originated in England, to the prudent man rule that was used by most states
in the 1960s and on to the prudent investor rule after promulgation of the
Uniform Prudent Investor Act in the early 1990s.
Rob S. described a number of tables that were shown to the audience that
present summary statistics on the change in portfolio allocation between
1986 and 1997 in trusts held by institutional trustees.
The FDIC collects annual data from institutional trustees that groups
investment allocations in personal trusts under several broad categories
such as "stock," "U.S. treasuries," and "municipal bonds."
Using the same state- and bank-level data from the FDIC, the presenters
found that after a state's adoption of the new prudent investor rule, trust
institutions in that state held about 2 to 4 percentage points more stock
at the expense of government bonds and other investments favored by the old
prudent man rule. This shift to stock represents a 3 to 10 percent increase
in stock holdings and accounts for roughly 10 to 30 percent of the overall
increase in stock holdings in the timeframe they studied. The transition to
the new, stock-heavier portfolio took roughly three years (a potentially
key finding for assessing breach and calculating damages).
He indicated by a chart that all states have now adopted the Uniform
Prudent Investor Act.
Rob S. described the implications of these statistics by suggesting that:
1. Default rules matter
2. Trustees are sensitive to changes in the law
3. The Prudent Investor Act is a welfare improving law
because it considers inflation risk
He also quoted from the Restatement (Third) of Trusts that damages will be
assessed on the basis of what it takes to "restore the value of the trust
to what it would have been but for the breach" and also cited Scott on
Trusts that also provides that damages will be a function of calculating
the loss based on what it takes to make a trust whole. He concluded that
these methods provide a better approach for calculating damages because
they do not inherently favor either the plaintiff or defendant in a lawsuit.
With the time remaining, Max S. reviewed one of two case studies provided
in the materials. In this case the facts were:
Ethel Pennywise, a 66-year-old widow, is co-trustee and the income
beneficiary of a marital trust originally funded in 1995 with $10 million
in cash. She has one son,
Reginald, who is the remainder beneficiary. Ethel and her co-trustee,
Generic Trust Company (GTC), initially invested $8 million of the trust
assets in U.S. Treasuries and
municipal bonds and the remaining $2 million in a broadly-diversified stock
fund. The portfolio has been rebalanced yearly to keep the trust's
portfolio allocation at 20 percent stock and 80 percent government
bonds. At the end of 2006, Ethel and GTC filed a formal accounting with
the court that showed a total trust value of $14.6 million, of which $3
million was held in stock and $11.6 in government bonds. Reginald objected,
alleging that the trustees violated the duties of prudence and
impartiality. Reginald claims that the trust should have been invested
one-half in stock from the outset. Accordingly, Reginald seeks damages in
the amount of $8.4 million, which represents the increase in value of what
$3 million invested in the S&P 500 in 1995 would have been worth in 2007.
(Between 1995 and 2007, the total return of the S&P 500 was 380 percent.)
Max S. discussed whether Ethel and/or GTC had committed a breach of trust
and focused on prudence, impartiality and the relevance of the trust
instrument language.
He then asked the question, assuming a breach had occurred, what was the
correct measure of damages and paid special attention to whether the
measure of damages depended on whether the breach is of the duty of
prudence, impartiality or both. He also reviewed potential benchmarks for
equity returns and the impact of rebalancing on the claim for damages. He
also pointed out that the time when a state adopts the Uniform Prudent
Investor Act will make a difference on the damages calculation and factored
in the need to account for fiduciary fees and other expenses that would
have been incurred during the administration of the trust.
The analysis of these factors resulted in Max S. being able to show that
Reginald was not entitled to any damages for the period that he challenged
the actions of the co-trustees.
The materials presented and the discussion of the impact of the Uniform
Prudent Investor Act both on the practices of trustees and on the
assessment of damages in actions for breach of trust were extremely
compelling and of great interest to all in attendance.
===========================================================
SPECIAL SESSION IV-B - INDIVIDUAL TRUSTEES AND DISCRETIONARY TRUSTS
Thursday, January 17, 2008
Presenters: Jon Gallo, John Price and Kenneth Feinfield
Reporter: Carol Sobczak
This panel discussion offered a good give-and-take between the
panelists and the audience, who asked many good questions. While many
points were made about a trustee's exercise of discretion, the bottom line
that the panelists all agreed upon was that communication is key.
* Communication between lawyers and their clients (what are your
client's intentions?)
* Communication with the trustee as translated into the trust document
to give the trustee guidance as to what you mean by "support," "education,"
"best interests," etc.
* Communication among family members (if you are going to treat your
children differently in your plan, tell them NOW to avoid discord LATER)
* Communication among family advisors (accountants, financial advisors,
insurance advisors, etc)
* Communication by trustee to all beneficiaries when one requests a
distribution (or use notice procedures under some state laws)
Besides communication, trustees appreciate exculpatory language in the
trust instrument.
Finally, the panelists all agreed that incentive trusts do more harm than
good. Mr. Gallo cited social and psychological studies which found that
using money as an incentive makes for depressed adults. We should remember
this the next time our clients ask us to draft incentive trusts.
====================================================
Special Session 4-E -Section 453, OID, Earnouts, Holdbacks, Price
Reductions, Escrows & Other Contingent Payments - What's This Got to do
with Estate Planning?
Thursday, January 17, 2008
Presenters: Michael Mulligan, Todd Steinberg and Gerald Hesch
Reporter: Joanne Hindel
The presenters took the audience through a series of examples using the
same basic facts for each example. In each case, a seller and a buyer were
engaged in a real estate transaction and the seller's amount realized,
basis and capital gain remained the same. The buyer's cost basis for the
asset was also the same in all the examples. What varied were the methods
they used to engage in the transaction.
In the first example, the buyer made a downpayment and then used an
installment note to purchase the balance of the asset. In the second
example the buyer did both of these things but also assumed mortgage
indebtedness of the seller. In the third example, the buyer assumed a
mortgage that exceeded the seller's cost basis in the asset. In the fourth
example, the buyer, in addition to all of the above, agreed to pay all
property taxes for the calendar year when due. In the fifth example, the
buyer agreed to pay for a fixed liability for environmental clean-up expenses.
In all of the examples, the presenters walked the audience through the
transactions from the seller's side - when could the seller recover his
basis in the property, when would he have to report that basis and could he
deduct anything from the transaction. They also presented from the buyer's
side with emphasis on when the buyer could acquire basis in the asset. In
each example they pointed out any lack of symmetry in the transaction such
as the seller having the ability to take a larger deduction than the buyer.
The presenters then discussed the installment method and contingent
liabilities and described four basic arrangements that give rise to
contingent liabilities for income tax purposes: earnouts, holdback; a
reduction in the sales price and escrows.
They discussed original issue discount (OID) implications and how to
determine the interest portion of each payment.
The presenters also compared OID to the installment method and discussed
the income tax ramifications and applicable methods of accounting reporting.
In the last segment of their presentation, they discussed estate planning
aspects of these types of transactions. They pointed out that if an
individual dies owning an installment obligation which includes contingent
rights, the obligation still must be valued for estate tax purposes even
though the contingent right has not been recognized for income tax
purposes. They also noted that an installment obligation on which gain has
been deferred and which is included in the seller's estate constitutes
income in respect of a decedent.
They also discussed lifetime planning considerations such as the fact that
a seller's gift of an installment obligation to another taxpayer generally
causes an acceleration of gain, necessitating the valuation both for gift
and income tax purposes of any outstanding contingent right due under the
obligation.
In the time remaining, they pointed out that use of techniques involving
grantor trusts such as GRATs and sales to defective trusts would generally
seem to be preferred in lifetime planning with respect to such installment
obligations.
====================================================
Steve Leimberg's Estate Planning Email Newsletter - Archive Message #1227
(Reprinted With Permission)
Date: 17-Jan-08
From: Steve Leimberg's Estate Planning Newsletter
Subject: Knight Court Heard From - 2% Sitcom Renewed for at Least One More
Season (of Regulations)
The ink hadn't dried on Ron Aucutt's accurate prediction in
LISI
Estate Planning Newsletter # 1222 before the
U.S.
Supreme Court confirmed it!
Ron not only called it right then but now provides us with an analysis of
what the just released Supreme Court decision means and where we go next!
Ronald D. Aucutt is a partner in the McLean, Virginia (Tysons Corner)
office of McGuireWoods LLP and is the group leader of the firm's trusts and
estates practice group where he has resolved tax issues through rulings and
technical advice in the Internal Revenue Service's National Office and in
administrative appeals throughout the country. He litigated the Scott case
cited below.
EXECUTIVE SUMMARY:
SUPREME COURT SUBJECTS FIDUCIARY INVESTMENT ADVISORY FEES TO THE 2% FLOOR
On January 16, 2008, the Supreme Court decided the "2% floor" case of
Knight v. Commissioner, known to many by its name of Rudkin in the Tax
Court and Second Circuit. In a unanimous (9-0) opinion by Chief Justice
Roberts, the Court affirmed the Second Circuit and held that trust
investment advisory fees are subject to the 2% floor of section 67(a).
In the words of section 67(e)(1), the Court held that a trustee's expenses
for investment advice are not "costs which are paid or incurred in
connection with the administration of the estate or trust and which would
not have been incurred if the property were not held in such trust or
estate" and therefore do not fall within the exception of that statute.
In the Court's view, section 67(e) excepts from the 2% floor "only those
costs that it would be uncommon (or unusual, or unlikely) for . a
hypothetical individual to incur."d
FACTS AND COMMENT:
A DIFFICULT OPINION PARSING A DIFFICULT STATUTE
The opinion, taken as a whole, is about what one might expect of a run at
tax law by jurists more familiar with First Amendment balancing. The Court
refused to give the "would not have been incurred" language of the statute
the "straightforward causation" significance the trustee advocated, because
"all (or nearly all) of a trust's expenses are incurred because the trustee
has a duty to incur them" and therefore a simple causation application
would render the "paid or incurred in connection with" language of the
statute "superfluous."
Of course, in support of this very argument the Court cites Bogert for the
proposition that all trust expenses "must be reasonably necessary to
facilitate administration of the trust," which sure looks like it makes the
"paid or incurred in connection with" language superfluous anyway.
But this point has not impressed other courts that have considered this
statute, and Government lawyers, who have championed the so-called
two-prong analysis, have never been phased by it either.
The Court's opinion will leave us bewildered in other ways too. Rejecting
the notion (apparently entertained by the Second Circuit) that "would not"
means "could not," the Court appears more inclined to the tests employed by
the Federal Circuit in Mellon Bank and the Fourth Circuit in Scott.
The Court reduces the operation of the statute to a simple question:
"whether a particular cost would have been incurred if the property were
held by an individual instead of a trust."
The Code has the word "not" in it, by the way, but if the Justices want to
look at this issue through the other end of the microscope, I suppose
that's okay - to whom can we appeal? Clearly the Court's tacit recognition
that this statute is so hopelessly clumsy it has to be turned upside down
to be read is at least an intellectual victory for taxpayers.
It looks as if the Court's approach is to imagine, hypothetically, that the
property in question were not held in trust and then ask if the expense in
question "would" (or "not"?) have been incurred by the individual owning
it. We must make "a prediction" - the Court's word. Investment advice,
the Court continues, is not "unusual" (as in weird?) for an individual to
incur. Therefore - this the Court doesn't explicitly say but necessarily
assumes - such a choice by an individual must be most likely or most
probable.
We all missed the part of the record that supported such behavioral
analysis - but not to worry, it is now settled as a matter of law. Would
that the "more likely than not" standard of tax opinions could be so easily
satisfied! The ABA Tax Section, which meets this weekend in Las Vegas,
will be in an ideal environment to evaluate such probability calculus.
Anyway, noting that Mr. Knight himself had cited the "prudent investor"
rule to justify his decision as trustee to seek investment advice, the
Court concluded:
[W]e have no reason to doubt the Trustee's claim that a hypothetical
prudent investor in his position would have solicited investment advice,
just as he did. Having accepted all this, it is quite difficult to say
that investment advisory fees "would not have been incurred"-that is, that
it would be unusual or uncommon for such fees to have been incurred-if the
property were held by an individual investor with the same objectives as
the Trust in handling his own affairs.
"In his position"? "With the same objectives"? Isn't that what the cases
have been about - the proposition that individuals aren't in the "position"
of a fiduciary and typically don't have the same "objectives" as a
fiduciary? If so, then it is hard to read the Court's opinion as anything
other than a round trip back to where we all started, except that now our
analysis will use the words "position" and "objectives."
But the Justices are not pranksters, and that couldn't (wouldn't?) be the
answer. The Knight decision means that fiduciary investment advisory fees
are subject to the 2% floor.
AN OPEN DOOR TO ARGUING SPECIAL CIRCUMSTANCES
In a curious twist, however, the Court adds this paragraph to the end of
its opinion [citations to briefs omitted]:
As the Solicitor General concedes, some trust-related investment advisory
fees may be fully deductible "if an investment advisor were to impose a
special, additional charge applicable only to its fiduciary
accounts." There is nothing in the record, however, to suggest that [the
investment adviser] charged the Trustee anything extra, or treated the
Trust any differently than it would have treated an individual with similar
objectives, because of the Trustee's fiduciary obligations. It is
conceivable, moreover, that a trust may have an unusual investment
objective, or may require a specialized balancing of the interests of
various parties, such that a reasonable comparison with individual
investors would be improper. In such a case, the incremental cost of
expert advice beyond what would normally be required for the ordinary
taxpayer would not be subject to the 2% floor. Here, however, the Trust
has not asserted that its investment objective or its requisite balancing
of competing interests was distinctive. Accordingly, we conclude that the
investment advisory fees incurred by the Trust are subject to the 2% floor.
Of course, the "balancing of the interests of various parties" is a major
defining characteristic of the role of most trustees, distinguishing them
from individuals. Leaving that aside, however, the suggestion that some
"incremental" costs of fiduciary investment advice might escape the 2%
floor even under the Court's approach is fascinating. While the resulting
complexity should be deplored, it is now apparently possible that trustees
themselves can employ a bit of self-help "unbundling" to identify such
fully-deductible "incremental" costs.
ANOTHER OPEN DOOR - TO REGULATIONS
The Court supported its view of section 67(e) by quoting the statement in
its 1989 opinion in Commissioner v. Clark that "[g]iven that Congress has
enacted a general rule ., we should not eviscerate that legislative
judgment through an expansive reading of a somewhat ambiguous
exception." After embracing an "unusual or uncommon" standard for applying
section 67(e), the Court said that "[w]e appreciate that the inquiry into
what is common may not be as easy in other cases, particularly given the
absence of regulatory guidance. . Congress's decision to phrase the
pertinent inquiry in terms of a prediction about a hypothetical situation
inevitably entails some uncertainty, but that is no excuse for judicial
amendment of the statute."
These references to "a somewhat ambiguous exception," "uncertainty," and
"the absence of regulatory guidance" leave the door open - I could (and
would!) say wide open - for Treasury to provide definitive practical
guidance. I continue to think there is absolutely no doubt that the
appropriate Treasury response is to abandon the harsh approach of the
proposed regulations and start over on the assumption that Congress's
concern with simplification in enacting section 67 demands that most trusts
be relieved from the administrative burdens the Supreme Court has
acknowledged. [See R.
Aucutt
Trusts
and the 2% Floor: Good Knight and Good Luck LISI Estate Planning
Newsletter # 1222]
It will be tempting for tax administrators to see the Government's 9-0
victory in Knight as a warrant for a sweeping crackdown on trusts. But it
is hard to believe that revenue agents in the field would view the sifting
of a trustee's admittedly legitimate expenses, coordination with DNI,
allocation among beneficiaries, flow-through to K-1s, and integration with
the beneficiaries' own 2% floors, often in the context of small numbers, as
an efficient use of resources.
THE VEXING ISSUE OF UNBUNDLING
There is nothing in the Knight opinion that requires "unbundling" of
unitary fiduciary fees. In fact, the opposite is true, as fiduciary fees
are not commonly paid by individuals.
The IRS is always free to demand unbundling in any case, and of course the
IRS has included an unbundling requirement in the proposed regulations.
Standing alone, unbundling can easily be justified as simply a way to make
sure that similarly situated taxpayers are treated similarly and that a
taxpayer cannot avoid a rule of tax law merely by mingling and
labeling. But invocation of such high-minded principles seems grotesquely
out of place where the underlying notion that section 67(a) applies to this
type of fiduciary expense is inconsistent with the purpose of the
statute. The idea that Congress, which enacted section 67 in large part to
relieve individuals of the burden of keeping track of such expenses would
thereby have intended fiduciaries who already keep track of such expenses
to now unpoach those expenses in certain arbitrary ways is just beyond
belief.
Whether it is also beyond the reach of the drafters of regulations remains
to be seen, but this writer chooses to still have faith.
HOPE THIS HELPS YOU HELP OTHERS MAKE A POSITIVE DIFFERENCE!
Ron Aucutt
CITE AS:
LISI Estate Planning Newsletter # 1227 (January 17, 2008) at
http://www.leimbergservices.com
Copyright 2007 Leimberg Information Services, Inc. (LISI). Reproduction in
Any Form or Forwarding to Any Person Prohibited - Without Express Permission.
CITES:
IRC §67; Michael J. Knight, Trustee v. Commissioner, 552 U.S. ___ (No.
06-1286, Jan. 16, 2008); William L. Rudkin Testamentary Trust v.
Commissioner, 467 F.3d 149 (2d Cir. 2006); Mellon Bank, N.A. v. United
States, 265 F.3d 1275 (Fed. Cir. 2001); Scott v. United States, 328 F.3d
132 (4th Cir. 2003); Commissioner v. Clark, 489 U. S. 726, 739 (1989), a
case involving the treatment of "boot" received in a "triangular merger" as
a dividend rather than capital gain under the exception in section 356(a)(2).
See also LISI Estate Planning Newsletters by Carol Cantrell, Steve Akers,
Ron Aucutt, Peter Rubin, and Bruce Steiner :
1217
,
1191
,
1167
,
1155
,
<1154
,
<1153
,
<1141
,
<1104
,
<1079
,
<1055
,
<1041
,
<940
,
<923
, and
<846.
====================================================
THE REPORTERS
Our on-site local reporters who are present in Orlando this year are Gene
Zuspann Esq. of Zuspann & Zuspann in Denver, Colorado; Joanne Hindel Esq.
of Fifth Third Bank in Cleveland, Ohio; Jason Havens Esq. of Howard, Mobley
& Havens PLLC in Florida and Tennessee; Kimon Karas Esq. of McCarthy,
Lebit, Crystal and Liffman Co., LPA in Cleveland, Ohio; Bruce Stone Esq. of
Goldman, Felcoski & Stone, PA in Coral Gables, Florida; Craig Dreyer Esq.
of McDonald Hopkins LLC in Cleveland, Ohio; Carol Sobczak Esq. of The Law
Offices of Carol A. Sobczak in St. Helena, California; Ronda Martinez Esq.
of Fifth Third Bank in Southfield, Michigan; and Mike Stiff Esq. of
Hutchins & Stiff LLC in Denver, Colorado. The editor again this year will
be Joseph G. Hodges Jr. Esq, a solo practitioner in Denver, Colorado, who
also is the Chief Moderator of the ABA-PTL List.
_________________________________________
GENERAL INFORMATION ABOUT INSTITUTE:
Inquiries/Registration:
Philip E. Heckerling Institute on Estate Planning
University of Miami School of Law
Center for Continuing Legal Education
P.O. Box 248087
Coral Gables, FL 33124-8087
Telephone: 305-284-4762 / FAX: 305-284-6752
Web site: www.law.miami.edu/heckerling
E-mail: heckerling@law.miami.edu
===========================================
Headquarters Hotel - Orlando World Center Marriott
8701 World Center Drive
Orlando, FL 32821
Telephone (407) 239-4200, FAX (407) 238-8777
==================================================
NOTICE: Although audio tapes of all of the substantive session at the Miami
Institute currently are only made available to Institute registrants for
purchase, the entire proceeding of the Institute are published annually by
Lexis/Nexis. For further information, go to their Web site at
http://www.lexisnexis.com/productsandservices. The text of these
proceedings is also available on CD ROM from Authority On-Demand by
LexisNexis Matthew Bender. For further information, contact your sales
representative, or call (800) 833-9844, or fax (518) 487-3584, or go to
http://www.bender.com, or write to Matthew Bender & Co., Inc., Attn: Order
Fulfillment Dept.,1275 Broadway, Albany, NY 12204.
|
