Did you Participate in a 419 or 412i Benefit Plan?
Lance Wallach is the nation's foremost expert on 419 plans, 412i plans, listed transactions, reportable transactions, Section 79 plans, captive Insurance plans
Plan Administrators Frustrated with IRS attacks with 8886 forms filed
I am a Third Party Administrator and am asking for your help. One of my clients with 4 employees who simply funded a retirement plan with $500,000 recently endured a 5.5 year IRS audit of his 412 (i) pension plan. Upon completion of the audit the client owes $55,000 in income taxes for 2004-2006 and has refunds from 2007-2008 of $55,000 (timing difference only) He owes about $30,000 in blackmail money (He really should owe nothing!). The SBSE income tax agent has threatened to assess $800,000 in penalties under Code Section 6707a. The IRS is far exceeding their authority in assessing the 6707a penalty this is totally prosecutorial abuse. WE must put a stop to this! My client cooperated and acted in good faith and did file the form 8886 (Maybe not 100% correctly but none the less, he did file the necessary forms).……
ReplyDeleteTo: Everyone I know!
It could be you.
I am a Third Party Administrator and am asking for your help. One of my clients with 4 employees who simply
funded a retirement plan with $500,000 recently endured a 5.5 year IRS audit of his 412 (i) pension plan. Upon
completion of the audit the client owes $55,000 in income taxes for 2004-2006 and has refunds from 2007-2008
of $55,000 (timing difference only) He owes about $30,000 in blackmail money (He really should owe nothing!).
The SBSE income tax agent has threatened to assess $800,000 in penalties under Code Section 6707a. The IRS
is far exceeding their authority in assessing the 6707a penalty this is totally prosecutorial abuse. WE must put a
stop to this! My client cooperated and acted in good faith and did file the form 8886 (Maybe not 100% correctly
but none the less, he did file the necessary forms).……
Dennis Cunning