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ReplyDeleteTracy Sunderlage invested clients money in a Ponzi scheme,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.Benistar,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,
Monday, March 24, 2014
IRS’s will get 419 412i and others twice under 6707A
Lance Wallach
How the IRS is taking a “formalistic approach” in interpreting its own section 6011 regulations on disclosing reportable transactions and not following its own rules on which tax years to assess the Section 6707A penalty.
The IRS is still assessing penalties under Code Section6707A, the penalty provision applicable to failure to disclose Congress-enacted reportable transactions taken since tax year 2004. Congress amended Section 6707A in 2010 to help alleviate its draconian consequences. They were fining people $100,000 per year on the personal level, and then fining the same parties $200,000 per year on the corporate level. I received phone calls from people who had put under $100,000 into 419, 412i or other plans. Some of them were being fined $600,000 or more under 6707A for failure to properly disclose using form 8886. Under newly amended Section 6707A, applicable to all penalties assessed after December 31, 2006, the penalty, subject to certain maximum and minimum amounts, is equal to 75% of the decrease in reported tax as a result of the reportable transaction. How the IRS is applying the Section 6707A penalty can be described as “troubling.”
Accountants would call me when their clients got audited for being in a 419, 412i, or other type of listed transaction. The client got audited and settled. The accountant thought they were finished with the IRS. When I told them that they were not they did not believe me. I have received hundreds of these types of phone calls. When I would speak at national accounting conventions, or legal conventions the people did not believe me. When I would write articles for national accounting or other publications people would call me and say it was not true. As an expert witness my side has never lost a case. Enough of this and on to the story.
The following case shows how troubling the IRS position is.
In 2004 and 2005, a taxpayer took deductions for life insurance premiums paid to a Code Section 419(e) plan (419(e) plan). Transactions similar to the 419(e) plan were declared “listed transactions” in Notice 2007-83 on October 17, 2007. Under the applicable version of Treasury Regulation § 1.6011-4(e)(2)(i), the taxpayer was required to file Form 8886 with its “next filed tax return” after the transaction became a listed transaction. Accordingly, the taxpayer was required to file Form 8886 with its 2007 tax return, which it filed on October 14, 2008. The taxpayer did not file Form 8886 with its 2007 tax return. On October 14, 2008, the taxpayer was under audit for its participation in the 419(e) plan.
An IRS letter dated January 15, 2008 informed the taxpayer that it was under examination because of its participation in a widely marketed 419(e) plan. The taxpayer gave the IRS agent (the