Report Part 18 (Thur., Fri. 1/18 & Tech)
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.
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This Report covers the Thursday afternoon Special Session 4-A on FLPs, the
first Friday morning regular session on Issue of Issue or The Child I Never
Had and the third and final Technology Report from Jason Havens. The next
Report will pick up on various missing reports and on some more of the
Friday morning sessions.
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Special Session 4-A - FLPs: Don't Leave Home Without One (But Leave Your
Home Outside of It!)
Thursday, January 17, 2008
Presenters: Stephanie Loomis-Price & Charles Hodges
Reporter: Mike Stiff
The presenters materials included a 20 page outline and a 59 slide
PowerPoint presentation which could be described as a must read users'
manual for attorneys and clients forming and operating FLPs. A very
detailed list of dos and don'ts.
The Table of Contents from their outline provides a succinct summary of
their 90 minute presentation and is reproduced below:
I. Introduction
II. Consider Appropriateness of Partnership
A. Keep potential future audience in mind
B. Consider whether clients are ready for partnership
C. Evaluate potential assets
D. Evaluate potential partners
E. Engage/consult with experienced advisors
III. Partnership Formation
A. Consider separate counsel for participants
B. Discuss partnership terms
C. Ensure agreement's schedules are complete
D. Prepare transfer documents in advance and file with relevant
state authorities
E. File for employer identification number
F. Create partnership accounts timely
G. Engage partnership accountant
H. Reflect contributions in capital accounts in proportion to fair
market value of assets contributed
I. Consider amortizing partnership set-up fees
J. If necessary, amend partnership percentages as quickly as
possible after formation
K. Be prepared to produce documents in your file to the IRS, if
necessary
IV. Partnership Maintenance
A. File accurate returns for each year in existence
B. File any required annual/bi-annual registration statements
C. Comply with terms of partnership agreement
D. Comply with loan terms, if loans are made
E. Make any distributions pro rata
F. Refrain from use of partnership assets for partners' personal
obligations
G. Upon transfers, consider whether to make a section 754 election
H. Avoid irregular transactions between partners and partnership
I. Keep in mind non-tax reasons stated for forming partnership
V. Transfers of Partnership Interests
A. Generally
B. By gift or sale
C. At death
D. By redemption
VI. Transfer Tax Reporting
A. Obtain Independent appraisal from qualified appraiser
B. Attorney/appraiser interaction
C. Confirm with appraiser the interest to be valued
D. Consider whether to aggregate interests
E. Review appraisal closely for facts
F. Try to live by factual information provided to appraiser
G. Beware of rounding on appraisals and tax returns
H. Understand IRS settlement guidelines
VII. Audit
A. Consider bringing in litigation counsel
B. Determine whether a document destruction policy exists, if so suspend
C. Consider the burden of proof
D. Consider the impact of privileges
E. Consider whether production of privileged information may help
your case
F. Provide responses to the IRS that are true and correct, to the
best of your knowledge
G. Keep in mind that anything stated or written at this stage can be
treated as an admission
H. Produce responsive documents in your possession, custody, or control
I. Keep careful track of every document and electronic file
produced to the IRS
J. Understand the IRS's broad subpoena power
K. File protective claims if necessary
L. Keep partnership in place
M. Treat informal interviews as depositions
As you can see the Table of Contents provides a very useful checklist to
practitioners. The presenters emphasized that most of the cases were the
IRS is having success involve very bad facts. Bad facts that can be easily
avoided by practitioners and their clients. Mr. Hodges stated that the 3
most common things that hurt a taxpayer's case is a bad letter, a bad email
or a bad memo. You have to keep the potential audience in mind in all
correspondence and communications. If done properly, the communications
between the client and the attorney (and other advisors) should be an asset
to the taxpayer, not a liability.
The non-tax reasons for creating FLPs are limitless but must be documented
and followed by the partners. Avoid laundry lists and templates. It is
fine to explain the tax consequences to clients if such discussions also
include the non-tax reasons.
Carefully evaluate assets being contributed. Think about planning
opportunities such as fractional interests and tiered discounts. Leave
personal use assets out of FLPs. If a client had a risky business, you
wouldn't advise the client to contribute his personal residence to the
business. So, keep personal homes out of FLPs. Although some advisors may
suggest that it is ok to contribute a vacation home if a fair market rent
is actually paid, the presenters warn this still looks bad and should be
avoided.
The presenters strongly recommended separate representation for all
partners involved. They also encourage all the partners to be involved
with the negotiation of the partnership agreement. It is important to
document the negotiations and any revisions requested by the various
partners. Ms. Loomis-Price stated that evidence of negotiation is the key
to beating a Section 2036 argument by the IRS. Similarly, Mr. Hodges
described evidence of negotiation as a silver bullet fact for the taxpayer
that can overcome many other bad facts.
There is no excuse for bad formation facts. Contribute assets immediately
after formation. Immediately establish and maintain capital
accounts. Once established, the terms of the partnership agreement should
be complied with and followed without exception.
This was an excellent program with two exceptional speakers.
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Issue of Issue or The Child I Never Had
Friday morning, January 18, 2008
Presenter: Gideon Rothschild
Reporter: Craig Dreyer
Mr. Rothschild mentioned the other title he was considering was "whose my
daddy?" It should be noted Mr. Rothschild's outline is very detailed and
covers an in depth exploration of the issues with detailed definitions of
many terms mentioned in this report. Mr. Rothschild started by noting in
the year 1978, the first test-tube baby was born and today many other
reproductive technologies have evolved. Even this week it was announced in
the news, the first clones of human cells were created.
These new technologies bring up interesting issues in the field of estate
planning. One should consider how these new technologies affect an
individual's ability to inherit. Today it is well established that if a
married couple conceives through assisted reproductive technology and the
child is born while the parents are alive, the child receives all the
benefits of descent. However, if a parent dies before contraception the law
is still very unsettled. He notes the time has arrived when these issues
must be resolved.
Until recently identifying the mother was easy and the father was presumed
to be the person the mother was married to. It is now possible to have five
parents. Two parents may raise the child and there can be a donated father
and two possible woman donors. Also, conception can take place years after
a biological parent has deceased. Women can freeze eggs for use over ten
years in the future. Banking sperm allows men to conceive children long
after they die. The inheritance issue is one of several critical aspects
left to resolve. In 2005, over 52,041 children were born using assisted
reproductive technology. Over 500 babies were born from previously frozen
eggs.
Assisted reproductive technology assists fertility and has expanded
throughout the years. There are various types of technologies that have
evolved to assist in fertility. The techniques discussed involve
cryopreservation, artificial insemination, in vitro fertilization, zygote
intrafallopian transfer (is fertilizing an egg in a laboratory and it is
placed in uterus), gamete intrafallopian transfer (transfer of unfertilized
ovum and sperm into fallopian tube), surrogacy tradition gestational, and
cloning.
With a posthumous child, the distinction must be made between those born
after a parent's death but conceived prior to death, and those who are
conceived or whose preserved embryo is implanted after a parent's death.
The law has long recognized pretermitted children. However, the current
issue of posthumously conceived children still has no coherent policy
approach to resolve inheritance rights. Other issues arise out of who will
have control over any cryopreserved specimens. There are three types of law
that have commonly dealt with these issues although all three do not
adequately deal with the current issue. The three areas that deal with
these legal issues are: 1) property law, 2) adoption law, and 3) family law.
In analogizing the new reproductive technologies, Mr. Rothschild
interestingly noted that the right of possession over a deceased remains
often go to the spouse or next of kin and is considered a quasi property
right. The right to a remains is only a right to disposition, and the
remains are considered property of the public domain. In addition to
possibly being a quasi property right, the status of cryopreserved cells is
more difficult since they may create new heirs as well. Property law
includes the right to exclude, posses, and profit from. For gametes this
may be appropriate. However for embryos and zygotes this property law does
not work, since two parties with an interest and there is a greater chance
for life.
Mr. Rothschild discussed the1984 CECOS case about a woman who wanted to
conceive a child posthumously. The clinic refused to give her the sperm
since no direction was provided with the donation. The court found the
sperm bank was in bailee status, but they also a fundamental right to
conception, which is a similar approach to embryos in the United States.
However, the French legislature later passed a law preventing such
posthumous conception.
Furthermore a California case, Hecht v. Super. Ct. (Hect I), 15 Cal.App.4th
836, 20 Cal. Rptr. 2d 275 (Cal Ct. App. 1993), stands for the proposition
that cryopreserved gametes are sufficiently proprietary in nature that
cryopreserved gametes may be included as part of the estate within the
jurisdiction of the probate court. Public policy did not prevent a single
woman from having a child posthumously from a husband. The court determined
Hecht had an interest to determine what happened to the sperm.
Today the legal status we use may determine whether a child may be created.
Neither property nor adoption law applies to zygotes or embryos. Property
law does not apply to embryos or zygotes since two people create them and
they have higher chance of life then gametes. Thus, neither adoption nor
property law can solely govern. Assisted reproduction as an alternative of
adoption has shifted the emphasis from the child's best interests to the
parent's rights against forced parenthood. Thus, if we focus on the child,
the child is protected for inheritance and other rights. If we focus on the
parents it is the right of the parents against forced parenthood.
In today's world of advances there is the traditional parenthood and then
the expanded legal parenthood. New technologies have even created the
possibility of uncoupled parenthood where multiple or no people may claim
parenthood. Public policy dictates a child should have two parents. New
techniques have undermined this principal. If one donates embryos then it
should be laid out in a contract, since the only sound approach appears to
be intent based reproduction. However, many issues remain. What about the
issue of posthumously conceived children? How should divorce affect these
issues? There is an argument posthumous rules should apply to divorce, but
others argue it is different. The distinction between the two is the
definiteness of the decisions. It is also important that society prevents
forced parenthood.
Other countries prevent posthumous children; some such as Israel set a time
limit. Britain mandates the destruction within a specified time period
without a written agreement to the contrary. Various uniform statutes in
the United States have attempted to reconcile these issues by addressing
the matter in an intent based approach. In an intent based approach,
consent may be withdrawn any time. Only 12 states have enacted these
posthumous statutes. Recommendations for drafting statutes include a
suggestion to use intent based statutes and also creating a time limit.
Mr. Rothschild notes a will should govern posthumously conceived children,
but many state intestacy laws fail to govern children posthumously
conceived. The three criteria one must consider in shaping these laws are:
1) the genetic makeup of an individual, 2) whether there was consent to
posthumous creation, and 3) one must clearly document consent to prevent
the misusing biological material to alter inheritance.
Furthermore, Mr. Rothschild notes posthumously conceived children could
destroy the ability for a class to close under the rule of perpetuities. It
would tie up estates to provide for children long after death. He noted
some suggest that only children born within a reasonable time period should
be an heir. Many states also require trusts to terminate within rule of
perpetuities. Posthumous children if born within nine-months are considered
legitimate heirs. The new law must deal with these issues, balancing the
various viewpoints.
Mr. Rothschild recommended a descendant's will or trust should clearly
provide their wishes to include children conceived through assisted
reproductive technology. If one does not want these posthumously conceived
children to inherit, one should clearly state this as well. Absent express
language of inclusion, children are determined to be inadvertently
pretermitted children. But the act of cryopreservation does not necessary
suggest a person wants to become a parent after death. Estate
administration could also continue forever. He notes there should be a
specified statute of limitations for inheritance. For a government
entitlement such as social security one must show dependency on parent at
death, but current state laws differ and result in unequal treatment of
children in certain circumstances.
Recently a case in Florida, Stephen v. Commissioner, said a posthumously
child cannot inherit unless named in the will. The Uniform Probate Code
provides conception prior to death is necessary; however, other draft
amendments may change this presumption. Only a few states have rules for
posthumously conceived children. In Louisiana a posthumous conceived child
can get death benefits if given permission and born within three years. The
state of California has a similar rule, and North Dakota statute prevents
posthumous conceived issue from receiving benefits. Thus, there is no clear
policy between the states.
Mr. Rothschild notes that science and technology will continue to evolve
and so must the law. Advances have extended fertility beyond the grave,
with corresponding consequences on the rule of perpetuities. This has
fundamentally changed the way the law must look at the issue of heirs and
opens a can of worms of ethical and moral, and legal and social issues.
Thus, the issue of posthumous born children should not be taken lightly. He
provided that the legislature must take action since the legal and social
fate of these children cannot be left indefinitely to the courts. In
drafting wills or trusts one should ask if they want to include these
provisions and also include a perpetuities savings clause.
Mr. Rothschild concluded with an amusing television clip illustrating the
complexities of law we are dealing with which could result in issues such
as "I am my own grandpa." These are the complex issues that will become
more complex as assisted reproductive technology continues to evolve.
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Technology Report #3
Reporter: Jason Havens
This is the final topical compilation to report interesting developments in
the technology/vendor area. This third and final topic in our coverage
features a few additional calculation and illustration software programs,
tax preparation/return software, and technological and other "tidbits" from
the vendor hall at the 42nd annual Heckerling Institute on Estate Planning.
Before we move to our final list of topics, please add the following to the
second report on "CALCULATION AND ILLUSTRATION PROGRAMS":
CALCULATION AND ILLUSTRATION PROGRAMS
There was a recent posting on the public WealthCounsel list entitled,
"Estate Planning Calculations/Presentations," by Stephanie Winstead,
Esq. She mentioned that she uses CCH's ViewPlan (Advanced), but that it
will only illustrate one planning technique at a time, e.g., a GRAT or a
CRT. She wants a program that will combine techniques and produce results
similar to ViewPlan Advanced.
This reporter would recommend IEP, which was covered in our last
report. Everyone should note that there is no "simple" program that
accomplishes this goal ... because the objective is far from
simple. However, IEP will illustrate a "baseline" plan along with
numerous permutations, which can either (a) compare planning techniques
side by side or (b) add one technique upon another to illustrate a
combination of various techniques. As this reporter has mentioned in other
reviews, IEP is the most comprehensive program on the market. It does
require a learning curve, as does any program, although the new user
interface makes that process much easier.
Incidentally, at a subscription of $900, IEP is also one of the most
affordable of the advanced calculation/illustration programs. A discount
is available at the Thomson/West booth for Institute attendees.
Now, to add to the second report's list:
(4) Brentmark (http://www.brentmark.com):
This reporter spent some time with Jane Schuck, who was regularly
demonstrating Brentmark's Kugler Estate Analyzer. The Kugler Estate
Analyzer will not only perform calculations, but will also simply
illustrate the addition of other techniques. Selecting "Assumptions"
within Kugler will reveal some of those calculation assumptions. The
output includes numerical illustrations, flowcharts, and explanations.
Brentmark has been working to update several of their retirement
calculation programs. The most popular, Retirement Plan Analyzer,
illustrates various strategies (showing up to four alternatives at one
time) of taking distributions from IRAs, Roth IRAs, Roth 401(k)s, and other
qualified retirement plans. This and Brentmark's other retirement
calculation programs have been updated for the Pension Protection Act of 2006.
(5) CCH ViewPlan Advanced (http://tax.cchgroup.com/ViewPlan/default.htm):
As mentioned above, ViewPlan Advanced is another advanced
calculation/illustration program. Contrary to the WealthCounsel posting,
this reporter believes that ViewPlan Advanced will indeed allow the
combination of more than one estate planning technique; however, this
reporter has not directly reviewed this program for a number of years. You
can enter extensive detail regarding the client's assets and liabilities.
You may then illustrate various preconfigured plans and/or add your own. In
fact, CCH has provided documentation and MP3 files to show you how this
works (via the link above); the second half of "Lesson 3" (direct links:
http://tax.cchgroup.com/ViewPlan/IntroductionViewPlan/Lesson3_Introduction.pdf
and
http://tax.cchgroup.com/ViewPlan/IntroductionViewPlan/VPTrainingLesson3Audio.mp3)
is the one to review regarding the illustration and addition (or
customization of preconfigured) of planning techniques.
It appears that neither Brentmark's Kugler Estate Analyzer nor CCH's
ViewPlan Advanced has been updated since late 2006. This is presumably due
to a "wait and see" approach regarding estate tax reform/repeal, coupled
(pun intended) with the fact that nothing has changed in terms of the
substance of transfer taxes. However, some state laws have
changed. Either program allows you to change those assumptions. Don
Kelley has actually updated IEP to reflect state law changes over the past
year. This reporter recommends that you try each of these to determine
which one best fits your practice.
(6) BNA Estate & Gift Tax Planner
(http://www.bnasoftware.com/product/default.aspx?prod=etplanner) and
IncomeTax Planner (http://www.bnasoftware.com/product/default.aspx?prod=itfs):
BNA also offers its award-winning planning software. In fact, Don Kelley
reviewed BNA's Estate & Gift Tax Planner in the October 2007 issue of
Estate Planning magazine. This program compares up to three scenarios
("cases") for a client. After entering asset and liability information,
which track the federal estate tax return, you may produce reports,
including flowcharts and PowerPoint presentations, to illustrate your
client's desired techniques.
TAX PREPARATION/RETURN SOFTWARE
As a preliminary note, this reporter does not directly prepare estate and
gift tax returns as a general rule (typically only providing review/advice
to CPAs who work with our clients). Consequently, Joe and/or Gene might
insert editorial comments regarding this portion of our tech
reports. Editor - none needed, as the popular ones are covered below
except for Thomson RIA's Fast Tax line of products.
(1) EstateWorks (http://www.estateworks.com):
Before we move into the actual tax preparation/return software, you need to
know about a couple of useful programs that complement your tax return
program. The first is EstateWorks. EstateWorks, which originally
debuted at the 2003 Institute based on this reporter's recollection,
neatly gathers all of the asset and liability information that you need to
produce probate pleadings as well as tax returns. EstateWorks' Probate
Plus currently produces probate pleadings (using the Internet-based server
edition of
HotDocs) for Connecticut, Florida, and Massachusetts. It also produces all
kinds of reports, such as a "snapshot" of the gross estate or a
beneficiary-based inheritance report (to show everyone what he/she will
receive), letters, and more. Importantly, EstateWorks' True Settlement
generates inventories and can serve as a case/practice management solution
by assigning tasks (with checklists) to various users.
EstateWorks currently exports to every major tax return software program
except for BNA (which is evidently in the works), e.g., Thomson Fast-Tax
FPS, FASTER Systems, Gillett Estate Management System, Intuit Lacerte,
Lackner 6-in-1, and CCH ProSystem fx. EstateWorks also integrates with
leading valuation programs, including Appraise and EstateVal.
(2) Estate Valuations & Pricing Systems, Inc. (EVP) (http://www.evpsys.com
or http://www.evpoffice.com):
These reports have consistently included and praised EVP for its adept
handling of valuations of securities/portfolios.
(3) Gillett Estate Management System (GEMS) (http://www.gillettpublishing.com):
It is impossible to cover all available software programs, but here are a
few of the favorite tax return applications. The most popular still seems
to be GEMS. The components of the system (GEM706, GEM709, or GEMAcct) are
only sold together as a complete system (not separately). GEMS has been
touted as a very user-friendly system that offers excellent customer
support. Their updates are released even before new draft forms are
finalized by the Internal Revenue Service. A demo is available online:
http://www.gillettpublishing.com/demo-dwnld.php. GEMS has existing
partnerships with EVP and ATX, the latter of which produces fiduciary
returns (Form 1041) seamlessly in conjunction with GEMS. Several state
modules are available. Users also seem to appreciate the competitive
pricing of GEMS ($1,295 or network $1,995), which is offered at a discount
to Institute attendees. GEMS was one of the products specifically
mentioned by Glen Yale in his excellent presentation on the federal gift
tax return.
(4) BNA 706 Preparer
(http://www.bnasoftware.com/product/content.aspx?display=706home) and 709
Preparer (http://www.bnasoftware.com/product/default.aspx?prod=709):
BNA's tax return programs are highly-rated and popular as well. You may
Google either/both to retrieve a number of reviews of these programs, e.g.,
http://www.cpasoftwarenews.com/article/article.jsp?id=738&siteSection=32
(THE CPA TECHNOLOGY ADVISOR (April/May 2007)). A demo of each is available
via the BNA website (contact information required), as is the product
documentation in PDF format (no information required).
(5) Lackner 6-in-1 Estate and Trust Administration
(http://www.lacknergroup.com):
Besides calculation programs developed with Steve Leimberg, Vince Lackner's
powerful system prepares all federal returns in this area of practice (706,
709, and 1041) and most state fiduciary income tax returns. The system
also produces inventories and accountings (trustee's and/or personal
representative's). Notably, the modules are available separately or as a
complete system and are also available for Windows or Mac operating
systems. (Incidentally, this reporter has purchased an Intel Core 2
Duo-based MacBook, which might be the first of many Apple computers for our
office.) Lackner's 6-in-1 system is powered by the ultra-stable FileMaker
Pro database. As with other programs, each Lackner component is discounted
by 10% for Institute attendees. Lackner 6-in-1 was the other product
specifically mentioned by Glen Yale in his 709 presentation, which
apparently generated welcome traffic!
OTHER TECHNOLOGICAL AND VENDOR HALL "TIDBITS"
(1) LexisNexis (http://bookstore.lexis.com/bookstore/catalog):
LexisNexis (Matthew Bender) is the exclusive publisher of the Institute's
proceedings, as usual, which are available via an electronic subscription if
desired (back to the 27th Institute).
(2) Banks and trust companies:
In recent years, financial institutions have been prevalent exhibitors at
the Institute. Several also serve as Platinum Sponsors of this year's
Institute and are listed below:
ARIS (http://www.ariscorporation.com)
BNY Mellon Wealth Management
(http://www.bnymellon.com/products/wealthmanagement/index.html)
Circa (http://www.circajewels.com)
Citi Trust (http://www.citibank.com/privatebank/trust_fiduciary.htm)
Coventry (http://www.coventry.com/)
Global Consultants and Services Limited (http://www.gcsl.info)
Harris Private Bank
(http://www.theharris.com/Private_Banking/Private_Banking.asp)
LexisNexis (http://www.lexis.com)
Liberty Art Title (http://www.libertytitle.biz/)
Life Options LLC (http://www.lifeoptionsllc.com/)
U.S. Trust Bank of America Private Wealth Management and Practical Drafting
(http://www.bankofamerica.com/privatebank)
Virgin Money (http://www.virginmoneyus.com/)
Several of these sponsors hosted popular events for attendees, including
lunches, dinners and other entertainment events.
(3) Location of the vendor hall and the Institute:
Overall, everyone seemed to enjoy the Institute as much as always. The
vendors also generally commented that this year's exhibit hall was
well-organized and met their expectations.
====================================================
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
===========================================
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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
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