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message 1: by Lance (new)

Lance Wallach One prominent promoter/TPA of 419 plans was Tracy Sunderlage out of the Chicago area.

Final Judgment and Permanent Injunction—the Tax Division of the U.S. Department of Justice was after Mr. Sunderlage and his companies.

On February 28, 2012, John Darrah, U.S. District Judge, signed a final order and permanent injunction with the agreement and approval of Mr. Sunderlage. The injunction is what’s really interesting. It bars Mr. Sunderlage from promoting, selling, acting as trustee or administrator for, or otherwise organizing, administering, or implementing:

-the PBT Multiple Employer 419 Plan and/or the Maven Structure described in the complaint.

-any plan or arrangement that is similar to the PBT Multiple Employer 419 Plan and/or the Maven Structure, including any plan or arrangement that claims to be a welfare benefit plan or to allow an employer to make a deductible contribution to a welfare benefit fund under I.R.C. Section 419 and/or I.R.C Section 419A.

-any plan that assists others to violate or attempt to violate the internal revenue laws or unlawfully evading the assessment or collection of one’s federal tax liabilities.

The above are just three of the restrictions that Mr. Sunderlage agreed to. There are three more; but for the sake of brevity, I’ve listed the above which should get my point across.

Complaint below:

http://www.globalstrategicadvisors.co...

What can we learn from the crashing and burning of 419 plans?

You’ve heard the saying that pigs get slaughtered? That’s exactly what we can learn from 419 plans. Once upon a time, 419 plans were done correctly. However, when the greed that revolved around life insurance commissions took hold, many unscrupulous firms entered the marketplace and sold non-compliant plans that allowed the IRS to eventually put the death nail in the heart of 419 plans.


message 2: by Lance (new)

Lance Wallach Lance Wallach, The Tax Resolution Offices of Lance ... - Viadeo.com
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message 3: by Lance (new)

Lance Wallach Abusive Tax Shelters & 419 Plans Lawsuits
412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.

Tuesday, March 18, 2014

IRS tax relief firm, Lance Wallach, speaking: FBAR/OVDI LANCE WALLACH: The IRS has kicked out an...
IRS tax relief firm, Lance Wallach, speaking: FBAR/OVDI LANCE WALLACH: The IRS has kicked out an...: FBAR/OVDI LANCE WALLACH: The IRS has kicked out an undisclosed number of ta... : Lance Wallach We have written at least 75 posts about ...


message 4: by Lance (new)

Lance Wallach Massachusetts Society of Certified Public Accounts, Inc.
Winter

IRS Attacks Business Owners in 419, 412, Section 79 and Captive Insurance Plans Under Section 6707A

By Lance Wallach



Taxpayers who previously adopted 419, 412i, captive

insurance or Section 79 plans are in big trouble.



In recent years, the IRS has identified many of these arrangements as abusive devices to funnel tax deductible dollars to shareholders and classified these arrangements as listed transactions." These plans were sold by insurance agents, financial planners, accountants and attorneys seeking large life insurance commissions. In general, taxpayers who engage in a “listed transaction” must report such transaction to the IRS on Form 8886 every year that they “participate” in the transaction, and you do not necessarily have to make a contribution or claim a tax deduction to participate. Section 6707A of the Code imposes severe penalties for failure to file Form 8886 with respect to a listed transaction. But you are also in trouble if you file incorrectly. I have received numerous phone calls from business owners who filed and still got fined. Not only do you have to file Form 8886, but it also has to be prepared correctly. I only know of two people in the U.S. who have filed these forms properly for clients. They tell me that was after hundreds of hou


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