Expert Witness and 419 Plans Litigation - IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS
Expert Witness and 419 Plans Litigation - IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS
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ReplyDeleted by small companies and funded with life insurance. For that reason taxpayers throughout the country seek his services in dealing with the Internal Revenue Service in audits, appeals and in the Tax Court. We can help you deal with: audits, appeals and Tax Court issues involving 419 Plan deductions and the taxation of withdrawals listed transaction issues including filing Form 8886 and fighting the section 6707A penalties Picture Some of the 419 Welfare Benefit Plans that have attracted attention of the IRS (rightly or wrongly) and others lately and over the past several years are: NOVA Benefit Plans (run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others), including: the SADI Plan, the Grist Mill Plan, Life One, among others Benistar Plans (also run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others) Greater Metropolitan Niche Marketing Millenium Plans CJA & Associates (run by Raymond Ankner Sea Nine VEBA Compass Welfare Benefit Plan Sunderlage Resource Group/SRG International (run by Tracy Sunderlage, among others)
Publish a post
ReplyDeleted by small companies and funded with life insurance. For that reason taxpayers throughout the country seek his services in dealing with the Internal Revenue Service in audits, appeals and in the Tax Court. We can help you deal with: audits, appeals and Tax Court issues involving 419 Plan deductions and the taxation of withdrawals listed transaction issues including filing Form 8886 and fighting the section 6707A penalties Picture Some of the 419 Welfare Benefit Plans that have attracted attention of the IRS (rightly or wrongly) and others lately and over the past several years are: NOVA Benefit Plans (run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others), including: the SADI Plan, the Grist Mill Plan, Life One, among others Benistar Plans (also run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others) Greater Metropolitan Niche Marketing Millenium Plans CJA & Associates (run by Raymond Ankner Sea Nine VEBA Compass Welfare Benefit Plan Sunderlage Resource Group/SRG International (run by Tracy Sunderlage, among others)
ADDITIONAL EMAILS WITH THE IRS
ReplyDeleteSent: Monday, November 28, 2011 2:01 PM
To: Itzkowitz Ronald R
Subject: Lance Wallach
Hope all is well with you. I never heard from your contact about the abusive shelter information that you sent to him. This stuff on section 79 and captive is not all over the net and is sold by the same promoters that used to sell the 412i and 419 scams??????
Lance Wallach
Sent: Monday, November 28, 2011 3:36 PM
To: Havicon Jon S
Cc: 'LAWALLACH@aol.com'
Subject: RE: Lance Wallach
Hi, Jon,
Would you please follow-up with your contact.
Thanks,
Ron
From:Jon Havicon
To: Lance Wallach
Sent: 12/22/2011 2:36 P.M.
Subj: IRC 79
Lance,
I heard back from my referral contact. She said if you know of any specific examples of abuse in this area, let me know and we'll forward the our Lead Development Center. Thanks.
Jon S. Havicon
Internal Revenue Agent
From: Lance Wallach
Sent: Friday, December 23, 2011 8:46 AM
To: Jon Havicon
Subject: Re: IRC 79
Dear Jon:
Many of the promoters of sect. 79 plans are the same people that promoted 419 and abusive 412i plans.
Most of the abuses, as of the prior plans, are in the face to face selling. Saying that the IRS approves the plans, putting large amounts of permanent life insurance in the plans and saying that it is deductible, etc. It is the same with the sales of captive insurance. They are telling the owners of the business that they can deduct large amounts of life insurance and in later years get the money out tax free. These promoters are a lot smarter about what they put in print, than in prior years. You may want to go on Google and type in Section 79 plans and see all the promoters and others.
In the 90s I warned about abusive 419 and 412i plans but the IRS did not do much to catch the abusers for years. In 2002 I spoke at ASPA in Washington, and then had a private meeting with senior IRS and Treasury officials which was arranged by the then acting IRS Comm. and arranged by MS. Gold, giving more details. Then the IRS really started going after all of the abusive 419 and 412i plans.This is the same pattern today.
Lance Wallach
From: Jon Havicon
Sent: Friday, December 23, 2011 9:46 AM
To: Lance Wallach
Subject: Re: IRC 79
Thanks for the update. I'll forward to our Lead Development Center for further review.
Jon S. Havicon
IRS Agent
ReplyDeleteLance Wallach, Managing Director, is the nation's leading expert on employee benefit plans,
tax problem resolution and IRS audit defense.
Mr. Wallach is a member of the AICPA faculty of teaching professionals & a renowned
national expert in many court cases. He is the author of many best selling financial & law
books, including:
* "Wealth Preservation Planning" by the National Society of Accountants
* "The CPA's Guide to Federal & Estate Gift Taxation" published by Bisk
* The AICPA's "The team approach to Tax, Financial & Estate planning."
* "The CPA's Guide to Life Insurance" by Bisk CPEasy
* Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot
spots by the AICPA, author/moderator Lance Wallach
ReplyDeleteLance Wallach, Managing Director, is the nation's leading expert on employee benefit plans,
tax problem resolution and IRS audit defense.
Mr. Wallach is a member of the AICPA faculty of teaching professionals & a renowned
national expert in many court cases. He is the author of many best selling financial & law
books, including:
* "Wealth Preservation Planning" by the National Society of Accountants
* "The CPA's Guide to Federal & Estate Gift Taxation" published by Bisk
* The AICPA's "The team approach to Tax, Financial & Estate planning."
* "The CPA's Guide to Life Insurance" by Bisk CPEasy
* Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot
spots by the AICPA, author/moderator Lance Wallach
ADDITIONAL EMAILS WITH THE IRS
ReplyDeleteSent: Monday, November 28, 2011 2:01 PM
To: Itzkowitz Ronald R
Subject: Lance Wallach
Hope all is well with you. I never heard from your contact about the abusive shelter information that you sent to him. This stuff on section 79 and captive is not all over the net and is sold by the same promoters that used to sell the 412i and 419 scams??????
Lance Wallach
Sent: Monday, November 28, 2011 3:36 PM
To: Havicon Jon S
Cc: 'LAWALLACH@aol.com'
Subject: RE: Lance Wallach
Hi, Jon,
Would you please follow-up with your contact.
Thanks,
Ron
From:Jon Havicon
To: Lance Wallach
Sent: 12/22/2011 2:36 P.M.
Subj: IRC 79
Lance,
I heard back from my referral contact. She said if you know of any specific examples of abuse in this area, let me know and we'll forward the our Lead Development Center. Thanks.
Jon S. Havicon
Internal Revenue Agent
From: Lance Wallach
Sent: Friday, December 23, 2011 8:46 AM
To: Jon Havicon
Subject: Re: IRC 79
Dear Jon:
Many of the promoters of sect. 79 plans are the same people that promoted 419 and abusive 412i plans.
Most of the abuses, as of the prior plans, are in the face to face selling. Saying that the IRS approves the plans, putting large amounts of permanent life insurance in the plans and saying that it is deductible, etc. It is the same with the sales of captive insurance. They are telling the owners of the business that they can deduct large amounts of life insurance and in later years get the money out tax free. These promoters are a lot smarter about what they put in print, than in prior years. You may want to go on Google and type in Section 79 plans and see all the promoters and others.
In the 90s I warned about abusive 419 and 412i plans but the IRS did not do much to catch the abusers for years. In 2002 I spoke at ASPA in Washington, and then had a private meeting with senior IRS and Treasury officials which was arranged by the then acting IRS Comm. and arranged by MS. Gold, giving more details. Then the IRS really started going after all of the abusive 419 and 412i plans.This is the same pattern today.
Lance Wallach
From: Jon Havicon
Sent: Friday, December 23, 2011 9:46 AM
To: Lance Wallach
Subject: Re: IRC 79
Thanks for the update. I'll forward to our Lead Development Center for further review.
Jon S. Havicon
IRS Agent
Thanks for sharing informative blog.
ReplyDeleteCPA expert witness