Recommend an ethical compliance strategy based on the client's comments about a valuation discount on the family limited partnership that is consistent with Internal Revenue Service (IRS) Circular 230 and the American Institute of Certified Public Accountants (AICPA) Code of Conduct.
Consider the client's cash constraints, economic impact over time, IRS Circular 230, and the AICPA Code of Conduct.
Develop an additional ethical compliance strategy that addresses the client's estate tax and the interest and penalty that will accrue if he does not make timely payments of tax.
Acknowledge appropriate tax case law and statutes.
Consider quantifying penalties and interest.