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Posts Tagged listed transaction

Abusive Tax Shelter Results In $100 Million Assessment

None of us enjoy receiving letters from the IRS. Some might argue and claim a refund is a nice thing to receive from the IRS but those checks come from the U.S. Treasury. While often a letter from the IRS signals an audit or notice saying that you owe more money, former HP board member [...]

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Former CPA Gets 3.5 Years in Prison, $100 Million Restitution For Tax Evasion Role

by Brian Mahany A former CPA and banker at Deutsche Bank AG was sentenced to 3-1/5 years and ordered to pay $115,700,000 for his role in helping clients evade taxes. David Parse will have to serve about 3 years before eligible for early release. He was convicted of mail fraud and obstruction charges. Prosecutors say [...]

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Tax Shelter Convictions Reversed; Big Loss For DOJ & IRS

by Brian Mahany The U.S. Department of Justice has suffered a number of defeats lately in white collar criminal cases. While the DOJ still boasts a conviction record that would make any prosecuting agency happy, going after tax cheats appears to be getting more difficult. It’s either that or the IRS is focusing on the [...]

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Time Running Out For Holders Of Welfare Benefit (419 or 412) Plans

by Brian Mahany We recently received two inquiries from people who purchased welfare benefit plans through Tracy Sunderlage. By now, folks invested in these plans probably know that their plan may well be a scam. To add insult to injury, the IRS also views most of these plans as listed transactions and abusive tax shelters. [...]

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419 Plan Holders Lose Major Appeals Court Decision

by Brian Mahany A decision last week may mean the end of any hope for relief by holders of welfare benefit plans. In April of last year, we reported on the Curcio decision in which the U.S. Tax Court ruled against 4 people that had purchased welfare benefit plans marketed by Benistar 419 Plan Services. [...]

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Don’t Become A Material Advisor

[Ed. Note - the following guest post is by Lance Wallach. The post originally appeared in Accounting Today on July 1st of this year and is being reprinted here at the request of its author. In his post, Lance details the dangers faced by accountants and others who prepare returns that involve abusive tax shelters. [...]

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Large IRS Fines Continue For 419, 412i, Captive Insurance and Section79 Plans

Guest Post by Lance Wallach Taxpayers must report certain transactions to the IRS under Section 6707A of the Tax Code, which was enacted in 2004 to help detect, deter, and shut down abusive tax shelter activities. For example, reportable transactions may include being in a 419,412i, or other insurance plan sold by insurance agents for tax [...]

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Uncle Sam Goes After Another Welfare Benefit Plan Scheme

by Brian Mahany The IRS and U.S. Department Justice Department have a special relationship with welfare benefit plan promoters and the brokers and insurance agents that sell them. They hate them.  For over a decade, the IRS has declared that many welfare benefit plans are fraudulent and abusive tax shelters. Many of the promoters are [...]

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U.S. Tax Court Disallows 419A Plan, Upholds Penalties

by Brian Mahany In a recent U.S. Tax Court case, taxpayers suffered a double loss. The taxpayers, consisting of four couples, had purchased welfare benefit plans marketed by Benistar 419 Plan Services. Under the plan, Benistar provided preretirement life insurance to select employees of companies enrolled in the plan. Small employers like the plans because [...]

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