Form 8971 Consistent Basis Reporting Requirements for Estates: Final Regulations, Schedule A, and Supplemental Reporting

Ms. Miller has nearly two decades of experience helping high net worth individuals and families navigate complex federal and state tax planning, estate and gift strategies, and federal tax controversy matters. Her clients include Fortune 500 public companies, privately held businesses, owners of closely held enterprises, family offices and individuals with inherited wealth. Ms. Miller has extensive experience representing clients in audits and examinations before the Internal Revenue Service (IRS), including administrative appeals and litigation in federal courts—most notably the U.S. Tax Court. Her practice spans all stages of civil tax controversy at both the federal and state levels, representing corporations, partnerships and individuals. She also advises on matters at the intersection of civil and criminal tax law. Ms. Miller has also assisted clients with high-stakes matters involving the disclosure of offshore accounts and unreported income from digital assets such as cryptocurrency. In the estate and gift tax space, she handles complex litigation involving the IRS, and she advises a broad range of tax-exempt organizations—including private foundations and public charities—on both compliance and controversy matters. In addition to her practice, Ms. Miller brings over 15 years of distinguished teaching experience to some of the nation's premier tax programs, including Georgetown University Law Center and Howard University School of Law, where she has shaped the next generation of tax practitioners. 

Mr. Sandler is a Tax Director at BPM with a specialty in estate and trust tax. He graduated from the University of California at Santa Cruz with a major in Political Science in 1992.