IRS Denies Error in Nixing $2.9B Deduction for Hilton Donation

Private Wealth Services attorney Patrick Duffey was mentioned in a Tax Notes article about the ongoing dispute between the estate of William Barron Hilton and the Internal Revenue System (IRS) over a $1.16 billion assessed estate tax deficiency. The dispute arose after the IRS denied the estate's $2.9 billion charitable deduction for a donation to the Conrad N. Hilton Foundation and certain administrative expense deductions. Mr. Duffey commented on the fundamental disagreements between the estate and the IRS, noting that the agency's denials and counter-allegations were not made lightly. He also found it remarkable that the IRS denied allegations related to the appointment of the personal representative, despite the relevant documents being public record and included with the estate tax return.

"Not only are the referenced proceedings a matter of public record, but the relevant documents would have been included with the estate tax return — indeed, the personal representative is the named party in the proceeding, and the letter of deficiency for which the IRS seeks approval is addressed to him," he said.

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