Be Careful What You Say (and Don't Do)! IRS Wins Step-Transaction Family Limited Partnership Case.

Sometimes clients wait on advice and then rush to implement planning for any of a number of reasons, ranging from a potential change in tax law to a health scare (like Mr. Smaldino). This can result in numerous risks, including the failure to document each phase or failure to let things settle before initiating the next phase. Risks are heightened during a time of potential tax law changes, coinciding with when advisors typically are busier than normal. Having a thought-out, meticulous, step-by-step master document to ensure each step is done and documented in the right order should be a best practice, particularly for sophisticated planning techniques. [ABSTRACT FROM AUTHOR]