Stout provided a valuation of a noncontrolling interest in the equity of a major U.S. winery for a taxable gift in 2013. Late in 2016, the IRS audited the gift tax return and called into question certain aspects of the valuation, including the concluded discount for lack of marketability, which exceeded 40%. Counsel for the client engaged our professionals to defend the 2013 appraisal against the IRS’ claims. We prepared a letter, which laid out a clear defense of the conclusions drawn in the 2013 valuation report. In mid-2017, after discussion with the client’s counsel and review of our defense letter, the IRS closed its audit and issued a no-change letter for the client’s taxable gift.