Nelson M. Blakely, Esq.

Nelson M. Blakely spent more than 30 years with IRS as an Estate Tax Attorney. Most of the last 20 years were spent running complex section 6166 computations for IRS service centers, providing computational support to many areas within the IRS and other branches of the Federal government including IRS Appeals, IRS Office of Chief Counsel, and the U.S. Department of Justice. He has run several thousand section 6166 computations.

Mr. Blakely reviewed and set up initial computations for all new 6166 elections received at Philadelphia Service Center and prepared initial section 6166 billing account information for the Accounting function. He processed section 6166 supplemental return recomputations; computed 6166 account payoff amounts for estates; and resolved general Service Center 6166 billing problems. In addition, he assisted field Estate Tax Attorneys in properly computing the changes to section 6166 elections upon the completion of their examinations. When nationwide estate tax return processing and section 6166 account maintenance were centralized at Cincinnati, he worked exclusively on section 6166 matters for Cincinnati Campus until his retirement.

He co-authored the 5 examples in Revenue Ruling 2006-34 and served on the National Estate and Gift Tax Policy staff project that drafted the Campus, Exam, and Advisory IRM provisions for section 6166 processing and section 6324A lien procedures. He was named the Section 6166 Subject Matter Expert on the IRS Estate and Gift Tax Intranet Resource Page and worked closely with IRS Office of Chief Counsel on bifurcated section 6166 election concepts.

Mr. Blakely has given numerous presentations for training and CLE purposes to IRS Estate Tax Attorneys and service center personnel and outside presentations before local bar association tax groups. He was a senior instructor in section 6166 concepts for Cincinnati Campus personnel and helped draft training materials on section 6166 for IRS Appeals Tax Computation Specialists.

Since entering private practice in 2010, he has provided detailed section 6166 computations, analyses, and advice to attorneys and accountants across the country, including the structuring of complex section 6166 election statements, and has assisted Department of Justice tax computation specialists with their estate tax computation programs. He also produced complex interrelated 6166 computations as a section 6166 expert witness for litigation involving a missed 6166 election.  

Johanna E. Blakely, Esq.

Johanna Blakely is an Estate Tax Consultant with Nelson M. Blakely, LLC and performs complex IRC Section 6166 computations for clients nationwide. Her background uniquely combines legal and technology project management experience, which gives her the ability to approach issues from various perspectives and uncover new solutions – a skill critical to supporting clients facing highly complex estate planning issues.

As a Bankruptcy Attorney with Spear & Hoffman, P.A., Ms. Blakely represented lender clients in bankruptcy and foreclosure matters. She represented secured creditors in Chapter 13 debtor cases in the U.S. District Court and U.S. Bankruptcy Court in New Jersey and prepared a variety of notices, complaints, motions, agreements, and contracts.

Ms. Blakely then joined Chicago Title Insurance Company and served as National Underwriting Counsel. There, she gained deep knowledge of tax and insurance law in various jurisdictions nationwide as she worked on projects involving complex real estate transactions. She organized multimillion-dollar sales and refinancing agreements, ensured compliance of title insurance policy limitations with state laws and procedures, and assessed legal and risk factors.

For six years, Ms. Blakely served as a project manager for a consulting company specializing in SaaS development and documentation for the retail industry. Working across technology and business teams, she successfully led efforts to modernize systems, support operations, and drive new business.

Ms. Blakely graduated from Widener University School of Law in 1999 and is admitted to practice in Pennsylvania and New Jersey.