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| "Tipping the scales of justice in your favor." |
| Defending and protecting businesses and financial professionals from IRS audits, Insurance companies and Brokerage firms. |
| Our Lawyers, CPAs & the Nation's Leading Financial experts will help you deal with IRS audits & all problems related to 419, 412i, section 79, captive insurance & other abusive insurance plans. We will work to recover your losses from the stock market & abusive insurance based plans from the insurance companies, brokerage firms & banks. |
The following are a small sample of the professional
books our Legal & Tax Audit Experts have authored:
New & best selling American Institute of Certified Public Accountants
books & courses:
Books by Bisk CPEasy, the nation's largest provider of Professional
education:
By the National Society of Accountants
books our Legal & Tax Audit Experts have authored:
New & best selling American Institute of Certified Public Accountants
books & courses:
- Avoiding Circular 230 Malpractice Traps and Common Abusive Small
Business Hot Spots - The Team Approach to Tax, Financial & Estate Planning
- Practical Alternatives to Commonly Misused and Abused Small
Business Tax Strategies: Ensuring Your Client's Future. - Fraud... Incompetence and Scams published by John Wiley and Sons
Books by Bisk CPEasy, the nation's largest provider of Professional
education:
- The CPA's Guide to Life Insurance
- The CPA's Guide to Federal & Estate Gift Taxation
By the National Society of Accountants
- Wealth Preservation Planning
| Email : LAWallach@aol.com |
| 516-938-5007 |
| The Law Offices of Mark Levinson ESQ. Copyright (C) 2011 Lawyer4Audits.com All rights reserved. |
Our Professional Services >>
Servicing Individuals and Businesses Nationwide.
- 419 & 412 plan defense
- Employee benefit plan audits/penalty resolution
- IRS Audit assistance
- Plan reviews, evaluations & remediation
- Expert Witness testimony
- FBAR undisclosed foreign asset reporting (IRS)
- Research & Analysis of Tax Laws
- Providing Guidance for Businesses, Attorneys, CPAs &
Insurance professionals nationwide. - Stock market, Mutual fund & Insurance loss recovery
- Life Settlement Lawsuits
- Premium Financing Lawsuits
- Retirement Plan Lawsuits
Servicing Individuals and Businesses Nationwide.
| A few of our recent successful resolutions for our clients: Click here |
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| "Our expert witness, Lance Wallach has never lost a case!" |
| Trusted Links: Attorneys-USA.org taxaudit419.com experttaxadvisors accountantexpert lancewallach.com reportable transactions.com taxlibrary.us |
Late breaking news: Large 419 plan files for Bankruptcy.
Recent court cases and other developments have highlighted serious problems in plans,
popularly know as Benistar, issued by Nova Benefit Plans of Simsbury, Connecticut. Recently
unsealed IRS criminal case information now raises concerns with other plans as well. If you have
any type plan issued by NOVA Benefit Plans, U.S. Benefits Group, Benefit Plan Advisors, Grist Mill
trusts, Rex Insurance Service or Benistar, get help at once. You may be subject to an audit or in
some cases, criminal prosecution.
On November 17th, 59 pages of search warrant materials were unsealed in the Nova Benefit
Plans litigation currently pending in the U.S. District Court for the District of Connecticut.
According to these documents, the IRS believes that Nova is involved in a significant criminal
conspiracy involving the crimes of Conspiracy to Impede the IRS and Assisting in the Preparation
of False Income Tax Returns. Read more here.
Recent court cases and other developments have highlighted serious problems in plans,
popularly know as Benistar, issued by Nova Benefit Plans of Simsbury, Connecticut. Recently
unsealed IRS criminal case information now raises concerns with other plans as well. If you have
any type plan issued by NOVA Benefit Plans, U.S. Benefits Group, Benefit Plan Advisors, Grist Mill
trusts, Rex Insurance Service or Benistar, get help at once. You may be subject to an audit or in
some cases, criminal prosecution.
On November 17th, 59 pages of search warrant materials were unsealed in the Nova Benefit
Plans litigation currently pending in the U.S. District Court for the District of Connecticut.
According to these documents, the IRS believes that Nova is involved in a significant criminal
conspiracy involving the crimes of Conspiracy to Impede the IRS and Assisting in the Preparation
of False Income Tax Returns. Read more here.
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 hours of research
and over 50 phones calls to various IRS personnel.
The filing instructions for Form 8886 presume a timely filling. Most people file late and follow the directions
for currently preparing the forms. Then the IRS fines
the business owner. The tax court does not have jurisdiction to abate or lower such penalties imposed by the
IRS. Read more here
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 hours of research
and over 50 phones calls to various IRS personnel.
The filing instructions for Form 8886 presume a timely filling. Most people file late and follow the directions
for currently preparing the forms. Then the IRS fines
the business owner. The tax court does not have jurisdiction to abate or lower such penalties imposed by the
IRS. Read more here
Breaking News: Don't Become A Material Advisor
Accountants, insurance professionals and others need to be careful that they don’t become what the IRS
calls material advisors. If they sell or give advice, or sign tax returns for abusive, listed or similar plans;
they risk a minimum $100,000 fine. Their client will then probably sue them after having dealt with the
IRS.
In 2010, the IRS raided the offices of Benistar in Simsbury, Conn., and seized the retirement benefit plan
administration firm’s files and records. In McGehee Family Clinic, the Tax Court ruled that a clinic and
shareholder’s investment in an employee benefit plan marketed under the name “Benistar” was a listed
transaction because it was substantially similar to the transaction described in Notice 95-34 (1995-1 C.
B. 309). This is at least the second case in which the court has ruled against the Benistar welfare benefit
plan, by denominating it a listed transaction.
The McGehee Family Clinic enrolled in the Benistar Plan in May 2001 and claimed deductions for
contributions to it in 2002 and 2005. The returns did not include a Form 8886, Reportable Transaction
Disclosure Statement, or similar disclosure. The IRS disallowed the latter deduction and adjusted the
2004 return of shareholder Robert Prosser and his wife to include the $50,000 payment to the plan.
Click here to read more.
Accountants, insurance professionals and others need to be careful that they don’t become what the IRS
calls material advisors. If they sell or give advice, or sign tax returns for abusive, listed or similar plans;
they risk a minimum $100,000 fine. Their client will then probably sue them after having dealt with the
IRS.
In 2010, the IRS raided the offices of Benistar in Simsbury, Conn., and seized the retirement benefit plan
administration firm’s files and records. In McGehee Family Clinic, the Tax Court ruled that a clinic and
shareholder’s investment in an employee benefit plan marketed under the name “Benistar” was a listed
transaction because it was substantially similar to the transaction described in Notice 95-34 (1995-1 C.
B. 309). This is at least the second case in which the court has ruled against the Benistar welfare benefit
plan, by denominating it a listed transaction.
The McGehee Family Clinic enrolled in the Benistar Plan in May 2001 and claimed deductions for
contributions to it in 2002 and 2005. The returns did not include a Form 8886, Reportable Transaction
Disclosure Statement, or similar disclosure. The IRS disallowed the latter deduction and adjusted the
2004 return of shareholder Robert Prosser and his wife to include the $50,000 payment to the plan.
Click here to read more.
How to Avoid IRS Fines for You and Your Clients
Published: 2010/2011
By Lance Wallach
Beware: The IRS is cracking down on small-business owners who participate in tax-reduction insurance plans sold by insurance
agents, including defined benefit retirement plans, IRAs, and even 401(k) plans with life insurance. In these cases, the business owner
is motivated by a large tax deduction; the insurance agent is motivated by a substantial commission.
A few years ago, I testified as an expert witness in a case in which a physician was in an abusive 401(k) plan with life insurance. It had
a so-called “springing cash value policy” in it. The IRS calls plans with these types of policies “listed transactions.” The judge called
the insurance agent “a crook.”
If your client was currently is in a 412(i), 419, captive insurance, or Section 79 plan, they may be in big trouble. Accountants who
signed a tax return for a client in one of these plans may be what the IRS calls a “material advisor” and subject to a maximum
$200,000 fine.
If you are an insurance professional who sold or advised on one of these plans, the same holds true for you. Read more here!
Published: 2010/2011
By Lance Wallach
Beware: The IRS is cracking down on small-business owners who participate in tax-reduction insurance plans sold by insurance
agents, including defined benefit retirement plans, IRAs, and even 401(k) plans with life insurance. In these cases, the business owner
is motivated by a large tax deduction; the insurance agent is motivated by a substantial commission.
A few years ago, I testified as an expert witness in a case in which a physician was in an abusive 401(k) plan with life insurance. It had
a so-called “springing cash value policy” in it. The IRS calls plans with these types of policies “listed transactions.” The judge called
the insurance agent “a crook.”
If your client was currently is in a 412(i), 419, captive insurance, or Section 79 plan, they may be in big trouble. Accountants who
signed a tax return for a client in one of these plans may be what the IRS calls a “material advisor” and subject to a maximum
$200,000 fine.
If you are an insurance professional who sold or advised on one of these plans, the same holds true for you. Read more here!
| FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED TO SEPTEMBER 9TH 2011! Specialty: People from India Breaking 419 plan news! U.S. District Attorney sues Maven LLC, Tracy Sunderlage & SRG International for promoting illegal 419 welfare benefit plans. Other plans face serious problems. Benistar raided by IRS. Millenium files for bankruptcy, Niche out of business. If you are in a 419, 412i, captive insurance, or section 79 scam, the time to seek competent, experienced help is now. |
Is opting out right for you? Click here to find out!
Our tax resolution
offices have
received calls
regarding the
following
companies or
plans: CJA, CJA
and Associates
offices have
received calls
regarding the
following
companies or
plans: CJA, CJA
and Associates