The IRS is cracking down on what it considers to be abusive tax shelters. Many of them are being marketed to small business owners by insurance professionals, financial planners and even accountants and attorneys. I speak at numerous conventions, for both business owners and accountants. After I speak, I am always approached by people from the audience who have questions about tax reduction plans that they have heard about.
Draconian Fines by IRS: Lance Wallach Expert Witness Services
Life insurance Litigation : About 5/15/2015, 12:04:00 PM Life insurance Litigation : About Form 8886, filing threshold 4/29/2015, 3:32:00 PM Form 8886, filing threshold 200k Penalty: Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000 5/15/2015, 4:02:00 PM 200k Penalty: Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000 Captive Insurance Plans | IRS Audit Representaion 5/15/2015, 4:01:00 PM Captive Insurance Plans | IRS Audit Representaion Google - Bookmarks 4/29/2015, 3:49:00 PM Google - Bookmarks ADDITIONAL EMAILS WITH THE IRS
Sent: 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
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.
Life insurance Litigation : About 5/15/2015, 12:04:00 PM Life insurance Litigation : About Form 8886, filing threshold 4/29/2015, 3:32:00 PM Form 8886, filing threshold 200k Penalty: Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000 5/15/2015, 4:02:00 PM 200k Penalty: Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000 Captive Insurance Plans | IRS Audit Representaion 5/15/2015, 4:01:00 PM Captive Insurance Plans | IRS Audit Representaion Google - Bookmarks 4/29/2015, 3:49:00 PM Google - Bookmarks ADDITIONAL EMAILS WITH THE IRS
Sent: 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
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.
ReplyDeleteLife insurance Litigation : About
5/15/2015, 12:04:00 PM
Life insurance Litigation : About
Form 8886, filing threshold
4/29/2015, 3:32:00 PM
Form 8886, filing threshold
200k Penalty: Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000
5/15/2015, 4:02:00 PM
200k Penalty: Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000
Captive Insurance Plans | IRS Audit Representaion
5/15/2015, 4:01:00 PM
Captive Insurance Plans | IRS Audit Representaion
Google - Bookmarks
4/29/2015, 3:49:00 PM
Google - Bookmarks
ADDITIONAL EMAILS WITH THE IRS
Sent: 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
ReplyDeleteLife insurance Litigation : About
5/15/2015, 12:04:00 PM
Life insurance Litigation : About
Form 8886, filing threshold
4/29/2015, 3:32:00 PM
Form 8886, filing threshold
200k Penalty: Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000
5/15/2015, 4:02:00 PM
200k Penalty: Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000
Captive Insurance Plans | IRS Audit Representaion
5/15/2015, 4:01:00 PM
Captive Insurance Plans | IRS Audit Representaion
Google - Bookmarks
4/29/2015, 3:49:00 PM
Google - Bookmarks
ADDITIONAL EMAILS WITH THE IRS
Sent: 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