“The smaller number of estate tax returns filed for deaths [occurring] in 2011 and 2012 will be subject to a heightened level of government scrutiny as IRS auditors comb through a declining inventory of returns to audit,” says Richard A. Behrendt (Robert W. Baird & Co.) in his article “Transfer of Interest in FLPs” (Trusts &  Estates, Aug. 2011, subscription required.)