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CJA And Associates
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SCAM CJA AND ASSOCIATED also CJA MARKETING
We too are victims of this scam
RUN from these people RAYMOND ANKNER and he band of cronies
You will get ripped off for hundreds of thousands of dollars plus face huge IRS penalties up to 200,000!!!
BEWARE and spread the word!!
just google RAYMOND ANKNER and look at all the lawsuits he has been in and lost
Do not be had by these perps
They claim to be experts in insurance and retirement plans but are experts in ripping off their victims with hundreds of thousands in commissions!
They have office in Chicago and Naples Florida
Ankner was CEO of largest insurance company bankruptcy in Illinois state history, he stuck his policy holders with 30 million in losses!
CJA and Associates got me audited
They issued a plan that I believed was a good deal and would provide adequate coverage for my employees and save me money on taxes. However it did not, I ended up getting audited by the IRS and having my employees sue me.
There is a class action suit being taken against these crooks for their captive insurance plan and as many people as possible should join in and put them out of business.
Luckily I reached out to Lance Wallach for help and was able to avoid bankruptcy. Visit http://cja.tax/ to learn more about how to get out from under the tragedy that CJA and associates heaped upon you.

Are u one, are u two, happy

Yep CJA is being sued by a bunch of its customers
Just google their CEO
Raymond Ankner and see his history of ripping people off for years
Run from these people and don't buy anything they are selling!!

Class Action Filed against CJA and Associates and Fidelity Security Life
Hartford, CT: A consumer fraud class action lawsuit has been filed against Chicago-based CJA and Associates and Kansas City, Missouri-based Fidelity Security Life Insurance Company (FSL).
The lawsuit alleges that CJA and FSL breached fiduciary duties in duping small business owners into investing millions of dollars of employee retirement benefit money in FSL annuities when up to 95% of the initial money invested was being siphoned off in commissions and fees.
The so-called Section 412 (e)(3) plans are under attack from the IRS as illegitimate attempts to avoid federal taxes.
The lawsuit alleges that by advising investment in these plans CJA and FSL breached federal laws governing advice given to employee benefit plans.
Plaintiffs are represented by Moukawsher & Walsh, LLC.
CJA and FSL Breach of Fiduciary Duties Class Action Legal Help If you or a loved one has suffered damages in this case, please click the link below and your complaint will be sent to a lawyer who may evaluate your claim at no cost or obligation.

how to get audited
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Published on July 18, 2017
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Lance Wallach
Lance Wallach Business Owner at National Offices of Lance Wallach "Niche" "Bisys" "Veba" "Doug Williams" "arch bonnema" "steve toth" "captive insurance" "michael sonnenberg" "ron snyder" "brian cave" "benistar" "norm bevan" "doug williams" " williams coulson" "dennis cunning" "phil rowe" "sadi trust" "beta plan" "millennium plan" "grist mill trust" "compass welfare benefit plan" "sea nine" "professional benefits trust" "integrity 419" "integrity benefit plan" "veba plan" "sterling 419" "judy carsrud" By Lance Wallach October 23, 2010 Welfare benefit plans (419), 412i, captive insurance and Section 79 plans are under intense IRS scrutiny and no matter what plan you were in, you surely need help now. The IRS has been cracking down on 419, 412i, listed transactions and virtually all plans, making it difficult for anyone who has been involved with one of these plans.
Listed below are some of the companies and names of salesmen,and others that you may recognize. Plan Names: Niche BiSYS Veba Benistar SADI trust Beta plan Millennium plan Grist Mill trust Compass welfare benefit plan Sea Nine veba Professional Benefits Trust Integrity 419 Integrity Benefit Plan Veba Plan Sterling 419 People, law firms, etc., affiliated with plans: Doug Williams Arch Bonnema Steve Toth Michael Sonnenberg Ron Snyder Brian Cave Norman Bevan Dennis Cunning Williams Coulson Phil Rowe Judy Carsrud Michael Lloyd Greeberg Tarig If you need help getting out of a plan, redoing a plan, or reviewing a plan, we can help you. We have written books about the subject, given hundreds of lectures and have worked on these problems for many years. Our team includes ex-IRS agents, tax attorneys, CPAs, Erisa attorneys and others substantially knowledgeable about these plans.
We have helped many others with these problems and look forward to helping you. LikedUnlikehow to get auditedCommentShareShare how to get audited Lance Wallach Lance Wallach Business Owner at National Offices of Lance Wallach 645 articles
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PRESIDENT
CJA SOLD US DEFECTIVE EMPLOYEE BENEFIT PLANS COSTING US HUNDREDS
OF THOUSANDS OF DOLLARS AND IRS AUDITS AND PENALTIES
ALL WHILE CJA WALKED AWAY WITH HUNDREDS OF THOUSANDS OF OUR DOLLARS IN COMMISSIONS
ALSO THE INSURANCE COMPANY FIDELITY SECURITY LIFE INSURANCE IS PART OF THIS SCHEME TO DEFRAUD COMPANIES OUT OF MILLIONS OF DOLLARS
THE IRS GOT LIST OF ALL OF CJA CUSTOMERS AND CAME AFTER THEM WITH AUDITS AND HUGE FINES, CJA HAS DONE NOTHING TO RECTIFY THEIR MISTAKE AND REFUSES TO GIVE BACK ANY MONEY OR ANY OF THE COMMISSIONS THEY TOOK AT THEIR CUSTOMERS EXPENSE AND EXPOSURE TO HUNDREDES OF THOUSANDS OF IRS PENALTIES

file 8886

cja and associates get sued audited and your money b ack
Published on Published onMarch 29, 2017
Stacey Arenas
Stacey Arenas
Following Following Stacey Arenas
Assistant Managing Director, Marketing Manager at Vebaplan LLC 573 articles Like 1 Comment 1 21 Lance Wallach Public May 22, 2014 I recieved this from someone that knew the owner of cjaand associates Dear Mr. Wallach, Great Article & Expose On CJA Marketing.
I Never Had Dealings With Them. I Did Meet The Ankners A Couple Of Times. They Reminded Me Of "Huckster Car Dealers From NJ". They Had Owned An On Line Bristol Trading Company Ebay Type Of Company.
As An Appraiser & Estate Specialist They Tried To "Freeload" Information From Me Under The Premise They Had A Vast Amount Of Estates That Required Appraisal Services. I Never Saw Anything During The 4 Years I Knew Them. I Sent Them Countless Referrals. That Lasted Maybe 6 Years.
I Found Them To Be Less Than Honorable. On The QT I Understand Jean. & Ray Ankner Are Divorcing. What Goes Around Comes Around.
God Speed On The Great Work You Are Doing. The Company Is Naples Based Now. They Had A Bristol Properties (Real Estate Company) That Closed In Boca In A Matter Of A Few Short Years. Words Of The Wise " Go With Your Gut Feeling" Best & Kind Regards, Patricia L.
Whiteside CJA and associates 419 412i section 79 scam audits lawsuits seniorabuses.blogspot.com one plus one 1 2 comments 2 no shares Shared publicly•View activity Lance Wallach Complaints Categories For Business Submit Complaint › Login Sign Up CJA and associates 419 412i section 79 scam audits lawsuits 2 of 2 Cja And Associates Reviews Issue not resolved 321 VIEWS 30 COMMENTS New York City, New York Life and Casualty Insurance Life Insurance Oct 24, 2012 review #353873 Robbendo www.taxaduit419.com for help with 419 plans IRS audits lawsuits of 419 412i captive insurance and section 79 plans|. California Enrolled Agent January 2, 2009 Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000 By Lance Wallach & Ira Kaplan Most insurance agents sell 412(i) retirement plans!. The large insurance commissions generate some of the enthusiasm'. Unlike other retirement plans, the 412(i) plan must have insurance products as the funding mechanism".
This seems to generate enthusiasm among insurance agents;. The IRS has been auditing almost all participants in 412(i) plans for the last few years,. At first, they thought all 412(i) plans were abusive. Many participants' contributions were disallowed and there were additional fines of $200,000 per year for the participants.
The accountants who signed the tax returns (who the IRS called "material advisors") were also fined $200,000 with a referral to the Office of Professional Responsibility. For more articles and details, see www.vebaplan.com and www.irs.gov/. On Friday February 13, 2004, the IRS issued proposed regulations concerning the valuation of insurance contracts in the context of qualified retirement plans. The IRS said that it is no longer reasonable to use the cash surrender value or the interpolated terminal reserve as the accurate value of a life insurance contract for income tax purposes.
The proposed regulations stated that the value of a life insurance contract in the context of qualified retirement plans should be the contract's fair market value. The Service acknowledged in the regulations (and in a revenue procedure issued simultaneously) that the fair market value standard could create some confusion among taxpayers. They addressed this possibility by describing a safe harbor position. When I addressed the American Society of Pension Actuaries Annual National Convention, the IRS chief actuary also spoke about attacking abusive 412(i) pensions.
A "Section 412(i) plan" is a tax-qualified retirement plan that is funded entirely by a life insurance contract or an annuity. The employer claims tax deductions for contributions that are used by the plan to pay premiums on an insurance contract covering an employee. The plan may hold the contract until the employee dies, or it may distribute or sell the contract to the employee at a specific point, such as when the employee retires. "The guidance targets specific abuses occurring with Section 412(i) plans", stated Assistant Secretary for Tax Policy Pam Olson.
"There are many legitimate Section 412(i) plans, but some push the envelope, claiming tax results for employees and employers that do not reflect the underlying economics of the arrangements." Or, to put it another way, tax deductions are being claimed, in some cases, that the Service does not feel are reasonable given the taxpayer's facts and circumstances. "Again and again, we've uncovered abusive tax avoidance transactions that game the system to the detriment of those who play by the rules," said IRS Commissioner Mark W. Everson. The IRS has warned against Section 412(i) defined benefit pension plans, named for the former IRC section governing them.
It warned against certain trust arrangements it deems abusive, some of which may be regarded as listed transactions. Falling into that category can result in taxpayers having to disclose such participation under pain of penalties, potentially reaching $100,000 for individuals and $200,000 for other taxpayers. Targets also include some retirement plans. One reason for the harsh treatment of 412(i) plans is their discrimination in favor of owners and key, highly compensated employees.
Also, the IRS does not consider the promised tax relief proportionate to the economic realities of these transactions. In general, IRS auditors divide audited plans into those they consider noncompliant and others they consider abusive. While the alternatives available to the sponsor of a noncompliant plan are problematic, it is frequently an option to keep the plan alive in some form while simultaneously hoping to minimize the financial fallout from penalties. The sponsor of an abusive plan can expect to be treated more harshly.
Although in some situations something can be salvaged, the possibility is definitely on the table of having to treat the plan as if it never existed, which of course triggers the full extent of back taxes, penalties and interest on all contributions that were made, not to mention leaving behind no retirement plan whatsoever. In addition, if the participant did not file Form 8886 and the accountant did not file Form 8918 (to report themselves), they would be fined $200,000. Lance Wallach, the National Society of Accountants Speaker of the Year, speaks and writes extensively about retirement plans, Circular 230 problems and tax reduction strategies. He speaks at more than 40 conventions annually, writes for over 50 publications and has written numerous best selling AICPA books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Business Hot Spots.
Contact him at 516.938.5007 or visit www.vebaplan.com. The information provided herein is not intended as legal, accounting, financial or any other type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice. bca8c3c Nov 20, 2014 Lance Wallach Raymond Ankner Insurance Raymond Ankner Expected to be the biggest life insurance failure in Illinois : IRS Attacks CJA and Associates’ plans, 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 Lance Wallach and his associates provide Expert Witness Services | Lance Wallach and his associates provide Expert Witness Services | Posted by Lance Wallach at 7/03/2014 12:33:00 PM Email This BlogThis! Share to Twitter Share to Facebook Share to Pinterest Labels: 412i, 419, captive insurance, Lance Wallach 9 comments: Lance WallachJuly 7, 2014 at 7:55 PM The Tax Audit Pros 5 1 6 - 9 3 8 - * * * * wallachinc@***.com AccountantExpert.org Lawyer4Audits.com VebaHealthCare.com TaxLibrary.us TaxAdvisorExperts.org lancewallach.com reportablletransaction.com Follow me on Copyright (C) 2010 - Lance Wallach Our team of experienced consulting "tax attorneys", CPAs, and "insurance experts" specializing in 412i" and "419 "IRS audits" that resulted from plans you sold to your clients, mainly "419 plans", "412i plans", "captive insurance" plans and "Section 79" plans as well as other similar "employee benefit plans" or "welfare benefit plans" that the IRS is targeting as "abusive tax shelters". Our firm has been successful in "defending life insurance agents" and "material advisors" who have participated in the sale of these "benefit plans". If you signed a return or participated in the sale of these "welfare benefit plans", you are probably a "material advisor" and subject to huge "IRS penalties and interest".
No "Form 8886" or "Form 8918" that we have reviewed for new clients has been properly prepared, which leaves the "material advisor" subject to the $200,000 "IRS penalty". We fight for our clients to defend against the $200,000 IRS "6707A penalty" by providing "expert witness testimony". Lance's side has never lost a case! ReplyDelete Lance WallachJuly 28, 2014 at 12:49 PM Raymond Ankner Reply Lance WallachOctober 1, 2014 at 1:13 PM our 419 plan fraud protection attorneys provide advice, counseling, and litigation representation for consumers who were harmed by defective 419 welfare benefit plans and the fraud and misrepresentation of plan promoters and insurance agents.
With offices in Washington D.C., Maryland, Virginia, and Florida, the firm represents consumers located throughout the U.S. What is a 419(e) welfare benefit plan? A 419(e) plan is a type of employee welfare benefit fund, sponsored by an employer, used for the purpose of providing financial stability for employees in retirement. These plans offer many different benefits to employees, including life, health, disability, long-term care, and post-retirement medical benefits.
In a 419(e) plan, there is no benefit pooling among different companies. Instead, the same company pays for all the plan benefits based on a target contribution or target benefit structure. Plan assets are generally held by an independent trustee, and are exempt from seizure by creditors of the company. How insurance companies scam consumers Despite the creation of regulations listing potentially abusive tax shelters (listed transactions) by the IRS, promoters continue to market plans to mislead consumers into believing the plan premiums are tax-deductible.
While this benefits the promoters and agents in their sales and commissions, it has serious financial consequences for consumers, including tax penalties and the loss of benefits because of defunct plans. Typical fraudulent claims of promoters include the following: Misrepresenting premiums as tax deductible Fraudulently claiming plans are exempt from tax deduction limits Failing to analyze whether insurance policies promoted are funds as defined by the IRC Incorrectly claiming exemptions from compliance with ERISA or sections 409, 414, 419, 505, and 79 of the IRC Improper tax deductions Failure to cite the section of the IRC under which contributions to their plan are tax-deductible Failed to comply with non-discrimination laws Taking larger deductions than required to pay term insurance costs for the current tax year Skilled 419 plan lawyers helping consumers When a 419 insurance plan is defunct, consumers who have paid high premiums for years are left without the promised benefits, including much needed life, health, disability, long-term care, and post-retirement medical benefits. In addition, fraud or misrepresentation of an insurance company and its plan promoter can result in penalties by the IRS and other serious tax consequences. Each 419 plan fraud protection ReplyDelete Lance WallachNovember 26, 2014 at 9:57 AM HARTFORD, Conn.-(BUSINESS WIRE)--Moukawsher & Walsh, LLC announced that today it filed a class action lawsuit against Chicago-based CJA and Associates and Kansas City, Missouri-based Fidelity Security Life Insurance Company (FSL).
The lawsuit alleges that CJA and FSL breached fiduciary duties in duping small business owners into investing millions of dollars of employee retirement benefit money in FSL annuities when up to 95% of the initial money invested was being siphoned off in commissions and fees. The so-called Section 412 (e)(3) plans are under attack from the IRS as illegitimate attempts to avoid federal taxes. The lawsuit alleges that by advising investment in these plans CJA and FSL breached federal laws governing advice given to employee benefit plans. Purchasers of CJA or FSL Section 412 (e)(3) plans are encouraged to contact Reply Robert ShermanMarch 24, 2016 at 11:27 AM Liquidation Comes For Lavish Insurer January 26, 1992|By Laurie Cohen.
379 In 1990 Chicago insurance executive Raymond Ankner flew about 100 of his top agents to Germany to celebrate Oktoberfest in Cologne. The cost of the trip was $800,000, billed to Ankner`s businesses. Most of those acquainted with him didn`t view the expensive junket or other lavish activities as out of line. To them, the red-haired, Brooklyn-born Ankner epitomized the successful insurance man, with a fast-growing operation, a company plane, homes in Florida and Vermont and an apartment in Water Tower Place.
But insurance regulators were already beginning to question expenses at his main insurance unit, InterAmerican Insurance Co. of Illinois. When the Illinois Insurance Department obtained a court order last month to liquidate the company, court papers showed a balance sheet crowded with overvalued real estate and questionable intercompany transactions and reinsurance arrangements. The collapse of InterAmerican is expected to be the biggest life insurance failure in Illinois history, with a gap of more than $30 million between assets and liabilities.
It has placed in the hands of state regulators the largest real estate and mortgage portfolio ever managed by the department. InterAmerican`s $33 million portfolio of mortgages and real estate covers several investments on Chicago`s Near West Side, including a loan on its headquarters at 901 W. Jackson Blvd. There also are more far-flung holdings, such as loans to donut shops in Michigan and a bed-and-breakfast in Vermont.
Nearly half the $20.5 million in mortgage loans are behind on payments, according to department officials. Regulators are still investigating the possibility that company funds were improperly used. No charges have been filed, and Ankner denies any suggestion of wrongdoing. A report by an independent accounta Reply Robert ShermanMarch 24, 2016 at 11:27 AM Liquidation Comes For Lavish Insurer January 26, 1992|By Laurie Cohen.
379 In 1990 Chicago insurance executive Raymond Ankner flew about 100 of his top agents to Germany to celebrate Oktoberfest in Cologne. The cost of the trip was $800,000, billed to Ankner`s businesses. Most of those acquainted with him didn`t view the expensive junket or other lavish activities as out of line. To them, the red-haired, Brooklyn-born Ankner epitomized the successful insurance man, with a fast-growing operation, a company plane, homes in Florida and Vermont and an apartment in Water Tower Place.
But insurance regulators were already beginning to question expenses at his main insurance unit, InterAmerican Insurance Co. of Illinois. When the Illinois Insurance Department obtained a court order last month to liquidate the company, court papers showed a balance sheet crowded with overvalued real estate and questionable intercompany transactions and reinsurance arrangements. The collapse of InterAmerican is expected to be the biggest life insurance failure in Illinois history, with a gap of more than $30 million between assets and liabilities.
It has placed in the hands of state regulators the largest real estate and mortgage portfolio ever managed by the department. InterAmerican`s $33 million portfolio of mortgages and real estate covers several investments on Chicago`s Near West Side, including a loan on its headquarters at 901 W. Jackson Blvd. There also are more far-flung holdings, such as loans to donut shops in Michigan and a bed-and-breakfast in Vermont.
Nearly half the $20.5 million in mortgage loans are behind on payments, according to department officials. Regulators are still investigating the possibility that company funds were improperly used. No charges have been filed, and Ankner denies any suggestion of wrongdoing. A report by an independent accounta Reply Robert ShermanMarch 24, 2016 at 11:28 AM Liquidation Comes For Lavish Insurer January 26, 1992|By Laurie Cohen.
379 In 1990 Chicago insurance executive Raymond Ankner flew about 100 of his top agents to Germany to celebrate Oktoberfest in Cologne. The cost of the trip was $800,000, billed to Ankner`s businesses. Most of those acquainted with him didn`t view the expensive junket or other lavish activities as out of line. To them, the red-haired, Brooklyn-born Ankner epitomized the successful insurance man, with a fast-growing operation, a company plane, homes in Florida and Vermont and an apartment in Water Tower Place.
But insurance regulators were already beginning to question expenses at his main insurance unit, InterAmerican Insurance Co. of Illinois. When the Illinois Insurance Department obtained a court order last month to liquidate the company, court papers showed a balance sheet crowded with overvalued real estate and questionable intercompany transactions and reinsurance arrangements. The collapse of InterAmerican is expected to be the biggest life insurance failure in Illinois history, with a gap of more than $30 million between assets and liabilities.
It has placed in the hands of state regulators the largest real estate and mortgage portfolio ever managed by the department. InterAmerican`s $33 million portfolio of mortgages and real estate covers several investments on Chicago`s Near West Side, including a loan on its headquarters at 901 W. Jackson Blvd. There also are more far-flung holdings, such as loans to donut shops in Michigan and a bed-and-breakfast in Vermont.
Nearly half the $20.5 million in mortgage loans are behind on payments, according to department officials. Regulators are still investigating the possibility that company funds were improperly used. No charges have been filed, and Ankner denies any suggestion of wrongdoing. A report by an independent accounta Reply Robert ShermanMarch 24, 2016 at 11:28 AM Liquidation Comes For Lavish Insurer January 26, 1992|By Laurie Cohen.
379 In 1990 Chicago insurance executive Raymond Ankner flew about 100 of his top agents to Germany to celebrate Oktoberfest in Cologne. The cost of the trip was $800,000, billed to Ankner`s businesses. Most of those acquainted with him didn`t view the expensive junket or other lavish activities as out of line. To them, the red-haired, Brooklyn-born Ankner epitomized the successful insurance man, with a fast-growing operation, a company plane, homes in Florida and Vermont and an apartment in Water Tower Place.
But insurance regulators were already beginning to question expenses at his main insurance unit, InterAmerican Insurance Co. of Illinois. When the Illinois Insurance Department obtained a court order last month to liquidate the company, court papers showed a balance sheet crowded with overvalued real estate and questionable intercompany transactions and reinsurance arrangements. The collapse of InterAmerican is expected to be the biggest life insurance failure in Illinois history, with a gap of more than $30 million between assets and liabilities.
It has placed in the hands of state regulators the largest real estate and mortgage portfolio ever managed by the department. InterAmerican`s $33 million portfolio of mortgages and real estate covers several investments on Chicago`s Near West Side, including a loan on its headquarters at 901 W. Jackson Blvd. There also are more far-flung holdings, such as loans to donut shops in Michigan and a bed-and-breakfast in Vermont.
Nearly half the $20.5 million in mortgage loans are behind on payments, according to department officials. Regulators are still investigating the possibility that company funds were improperly used. No charges have been filed, and Ankner denies any suggestion of wrongdoing. A report by an independent accounta Reply Lance WallachMarch 29, 2017 at 4:46 PM CJA And Associates - SCAM CJA AND ASSOCIATED also CJA MARKETING We too are victims of this scam RUN from these people RAYMOND ANKNER and he band of cronies You will get ripped off for hundreds of thousands of dollars plus face huge IRS penalties up to 200,000!!!
BEWARE and spread the word!! just google RAYMOND ANKNER and look at... Read more Comment 8 comments Helpful? Yes 4 No 0 Anonymous Anonymous n Filed against CJA and Associates and Fidelity Security LifeHartford, CT: A consumer fraud class action lawsuit has been filed against Chicago-based CJA and Associates and Ka...
Anonymous Anonymous cja lawsuits get your money backEdit articlePublished on September 14, 2016LikedUnlikecja lawsuits get your money back1Comment9ShareShare cja lawsuits get your money back0Lanc... CJA And Associates Greenville, South Carolina #737505 by anonymous Reply to reviews Jan 15, 2015CJA and Associates got me audited They issued a plan that I believed was a good deal and would provide adequate coverage for my employees and save me money on taxes. However it did not, I ended up getting audited by the IRS and having my employees sue me. There is a class action suit being taken...
Read more Comment 3 comments Helpful?
Yes 2 No 2 Anonymous Anonymous Class Action Filed against CJA and Associates and Fidelity Security LifeHartford, CT: A consumer fraud class action lawsuit has been filed against Chicago-based CJA and Associ... Anonymous Anonymous Yep CJA is being sued by a bunch of its customersJust google their CEORaymond Ankner and see his history of ripping people off for yearsRun from these people and don't buy any.

Submitted: Wed, December 11, 2013 Updated: Wed, December 11, 2013
Reported By: Pissed victim —
Fidelity Security Life Insurance
Kansas City, Missouri
USA
Phone: Web: Category: Insurance Companies Fidelity Security Life Insurance This company conspired with a 419 plan promoter CJA Marketing to promote fraudulent tax savings plans using their term and annuity products

The Inter-American Insurance Co. of Illinois (Inter-
American) specializes in providing to small, closely held
corporations products such as qualified pension and profit
sharing plans and group life insurance plans.
When Inter-
16 -
American was formed in the late 1970’s, it was owned indirectly by Beaven/Inter-American Cos., Inc. (Beaven/Inter-American), the wholly owned company of Raymond G. Ankner (Mr. Ankner), who has worked in the insurance industry for more than 30 years.
Inter- American liquidated on December 23, 1991, pursuant to a court order to do so, and Beaven/Inter-American changed its name to Beaven Cos., Inc.
Mr. Ankner currently markets the life insurance products described herein through a company of his called CJA & Associates.

Yep these are some bad people

CJA is a fraud
Run from this company they have a number of lawsuits against them
RUN! Beware

Raymond Ankner -Expected to be the biggest life insurance failure in Illinois
Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : IRS Attacks CJA & CJA and Associates’ plans, 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,
Saturday, November 30, 2013
Tax Crimes - Is the IRS Coming to Get You? Lance Wallach, expert witness.
People who have money in other countries are a target of the IRS.
I get a lot of phone calls with people who have these problems. 419, 412i, hiding money offshore etc. The IRS may be looking for you if you had anything to do with this. Tax crime attacks by the IRS are up almost 50% so you need to be careful.
Last year IRS raided the offices of Benistar, Grist Mill Trust, Nova with about 50 agents and took all the files. If you did business with them the IRS will probably come to you. The numbers are out and they aren’t good for people convicted of tax crimes. While the U.S.
Department of Justice Tax Division has always enjoyed a very high conviction rate, many people convicted of tax crimes never went to jail. Not anymore. In 2001, the average tax offender received a sentence of 18 months. Now those sentences average 25 months.
The statistics are a bit misleading because a decade ago, half the people convicted never went to jail. The average sentence may have been 18 months but many folks got house arrest while others received sentences of several years. Now, those convicted are probably going to jail. In other words, not only has the average sentence increased but also so has the likelihood of receiving a prison sentence.
Sentences in federal criminal cases are governed by the United States Sentencing Guidelines. Although no longer binding on judges, they are the court’s starting point and most judges’ stay within guidelines. The sentencing guidelines attempt to account for a wide range of factors including one’s criminal history, whether the defendant used “sophisticated means” to carry out the crime and whether the defendant took early acceptance of responsibility for his or her actions. For tax cases, the guidelines also look at “relevant conduct” tax loss.
The higher the tax loss, the longer the recommended sentence. The current guidelines impose suggest stiff penalties for tax crimes and many judges now believe that house arrest is not a strong enough deterrent to insure voluntary compliance. What does this mean for people with tax problems? Plenty.
First, if you know you have a problem, don’t bury your hand in the sand. The IRS operates on a “first contact” basis. That means if you come clean before you are caught, criminal penalties can generally be avoided. Second, if you are indicted and convicted, it pays to have a lawyer with extensive federal criminal tax appearance.
Adjustments to the sentencing guideline calculations often can mean the difference between prison and freedom.
Although there are many good lawyers that can negotiate a fair plea agreement, the final sentence is up to the court. Mastery of the federal sentencing guidelines and the thousands of court cases interpreting those guidelines separates great criminal tax lawyers from the rest of the pack

Class Action Filed against CJA and Associates and Fidelity ...
www.lawyersandsettlements.com/lawsuit/CJA-FSL-Class-Action.html - Similarto Class Action Filed against CJA and Associates and Fidelity ...
Aug 2, 2012 ...
Class Action Filed against CJA and Associates and Fidelity Security Life. Hartford , CT: A consumer fraud class action lawsuit has been filed ...
Ch 2: Appointment and Payment of Counsel - U.S. Courts
www.uscourts.gov/FederalCourts/AppointmentOfCounsel/CJAGuidelinesFor... - Similarto Ch 2: Appointment and Payment of Counsel - U.S.
Courts Part A Guidelines for Administering the CJA and Related Statutes ...... counsel who is not a partner or associate, within the maximum compensation allowed by ... [PDF] Plaintiffs' First Amended Complaint omit... https://www.paed.uscourts.gov/documents/opinions/05D1211P.pdf Sep 27, 2005 ...
(“CJA”), and the Travelers Life and Annuity Company (“Travelers”).1 Now ...
when [she] came across CJA and Associates as a provider” of ... [ More results from www.paed.uscourts.gov ]

CJA and Associates, Inc. - Naples, FL - Local Business | Facebook
https://www.facebook.com/pages/CJA-and-Associates.../138939****326...
CJA and Associates, Inc., Naples, FL.
121 likes · 5 talking about this · 7 were here. CJA is a national employee benefits company. We specialize in the design ...
TAXSHELTERAUDITS.ORG: IRS Attacks CJA & CJA and Associates ...
taxshelteraudits.org/2011/.../irs-attacks-cja--cja-and-associates-plans.aspx
Oct 14, 2011 - Lance Wallach. Our tax resolution offices have been alerted that taxpayers are starting to be contacted by the IRS concerning plans in ...
Lance Wallach shared this on Google+ Raymond Ankner -Expected to be the biggest life insurance failure ...
raymondanknerinsurance.blogspot.com/ Nov 30, 2013 - Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : IRS Attacks CJA & CJA and Associates' plans, 412i, 419e plans ... Lance Wallach shared this on Google+

as an expert lance wallach has never lost a case www.lancewallach.com
419 412i plans IRS audits lawsuits
Lance Wallach
director at taxaudit419.com
Plan names:
Benistar, SADI Trust,Beta 419,Millennium Plan,Bisys,Creative Services Group,Sterling Benefit Plan,Compass 419,Niche 419,CRESP,Sea Nine Veba, American Benefits Trust, National Benefit Plan and Trust, ABT, Professional Benefits Trust Benistar 419 Plan, nova trust, Grist mill trust, Sadi Trust IRS raids, Millennium 419 Plan,Bisys 419,Creative Services Group 419 Plan,Sterling Benefit 419 Plan,CRESP 419,Sea Nine Veba 419, National Benefit Plan and Trust 419, American Benefits Trust 419,ABT 419,Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life "Grist Mill Trust" "Real Veba""Section 79 GEAR" GEAR" "United Financial Group" "Kenny Hartstein" "Millennium Plan" Kenny Hartstein" "Millennium Plan" "Tom Crosswhite" "Greg Roper""captive insurance" cresp "Ridge Plan" "Professional benefits Trust" "PBT " "Professional Planning Associates" "National Pension Associate" "NPA""Heritage Plan" ""Insurance fraud""pension and benefit plan fraud""insurance company fraud""ECI Pension Services""Pension Professionals of America""ABI""Hartford""AIG""Indy Life""Indianapolis Life""Advantage" Names of People who SOLD: "Kenny Hartstein""Dennis Cunning""Steve Toth""Michael Sonnenberg"Larry Bell""Scott Ridge""Randall Smith""Greg Roper""Tracy Sunderlage""Warren Trust""Joseph Donnelly""Norm Bevan""Judy Carsrud""Dan Carpenter""Ed Waesche" "Tom Crosswhite""David Struckman""George Huff" "Tom Crosswhite" "Greg Roper""Christopher Jarvis" David Mandell" Gen Von Oder Insurance Companies -- need to be 412 AND 419: Hartford 419, Pacific Life 419, PAC Life 419, AVIVA, 419, Indianpolis Life, Penn Mutual419,Bankers Life 419, John Hancock 419, Security Mutual 419, Transamerica 419,Prudential 419, Kansas City Life 419, Mass Mutual419, Guardian 419, Amerus 419, Wells Fargo 419, Fifth Third Bank 419, Arrow Head Trust 419, U.S. Benefits Group, Benefit Plan Advisors, Rex Insurance Service,Advantage,AIG, Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life

It appears that CJA and Associates aka CJA Marketing has been sued
again, and again.
On Feb 28, 2013 in Northern Calif a suit was filed in California courts.
On Sept 26, 2013 in Northern Illinois s suit was filed in Illinois
There most likely be more to come! stay tuned!

CJA Marketing
Naples FL
Internet
United States of America
Phone: Web: Www.cjamarketing.com Category: Insurance Agencies CJA Marketing CJA and Associates Sold defective retirement plans costing us hundreds of thousands of dollars, Internet Print this ReportEmail this Report REBUTTAL BOX™ | Respond to this Report! Add Rebuttal to this ReportWhat's this?
Aribitrate & Set Record Straight File New ReportWhat's this? Repair Your ReputationWhat's this? 0 Author 0 Consumer 0 Employee/Owner Does your business have a bad reputation? Fix it the right way.
Corporate Advocacy Program™ SEO Reputation Management at its best! Beware of this company They are in big trouble with IRS and class action law suit pending This report was posted on Ripoff Report on 04/24/2013 06:18 PM and is a permanent record located here: http://www.ripoffreport.com/r/CJA-Marketing/internet/CJA-Marketing-CJA-and-Associates-Sold-defective-retirement-plans-costing-us-hundreds-of-th-104****.
The posting time indicated is Arizona local time. Arizona does not observe daylight savings so the post time may be Mountain or Pacific depending on the time of year.

www.taxaudit419.com for more
Trust Fraud
We were sold what was supposed to be tax deductible employee benefit trust plans that turned out to be disallowed by the IRS costing us hundreds of thousands of dollars in taxes, penalties and the company and agent that sold us got huge commissions on these bogus plans
We have had nothing but the run around from these people and they control the trust and make up all the rules to their benefit and leave their customers hanging and stuck with huge attorney fees and IRS penalties
Beware
If you have been damaged by these plans please leave info on this site and contact information

Lance stop posting articles and then commenting on your own article.

As an expert witness Lance Wallach has never lost a case. Google him or call 516 935**** to get your money back. He is all over the net helping people.

Tax Shelter Penalty Hurts Bizs
The IRS is cracking down on small businesses,!Captive Insurance,Benistar post-65 retiree benefits administration retiree medical and prescription drug plans solutions Brokers plan administration.
Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : Captive Insurance & 419 Plans Litigation: Septembe...
Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : Captive Insurance & 419 Plans Litigation: Septembe...: Captive Insurance & 419 Plans Litigation: September 2013
CJA and associates 419 412i section 79 scam audits lawsuits
www.taxaduit419.com for help with 419 plans IRS audits lawsuits of 419 412i captive insurance and section 79 plans|.
California Enrolled Agent
January 2, 2009
Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000
By Lance Wallach & Ira Kaplan
Most insurance agents sell 412(i) retirement plans!. The large insurance commissions generate some of the enthusiasm'. Unlike other retirement plans, the 412(i) plan must have insurance products as the funding mechanism". This seems to generate enthusiasm among insurance agents;. The IRS has been auditing almost all participants in 412(i) plans for the last few years,. At first, they thought all 412(i) plans were abusive. Many participants' contributions were disallowed and there were additional fines of $200,000 per year for the participants. The accountants who signed the tax returns (who the IRS called "material advisors") were also fined $200,000 with a referral to the Office of Professional Responsibility. For more articles and details, see www.vebaplan.com and www.irs.gov/.
On Friday February 13, 2004, the IRS issued proposed regulations concerning the valuation of insurance contracts in the context of qualified retirement plans.
The IRS said that it is no longer reasonable to use the cash surrender value or the interpolated terminal reserve as the accurate value of a life insurance contract for income tax purposes. The proposed regulations stated that the value of a life insurance contract in the context of qualified retirement plans should be the contract's fair market value.
The Service acknowledged in the regulations (and in a revenue procedure issued simultaneously) that the fair market value standard could create some confusion among taxpayers. They addressed this possibility by describing a safe harbor position.
When I addressed the American Society of Pension Actuaries Annual National Convention, the IRS chief actuary also spoke about attacking abusive 412(i) pensions.
A "Section 412(i) plan" is a tax-qualified retirement plan that is funded entirely by a life insurance contract or an annuity. The employer claims tax deductions for contributions that are used by the plan to pay premiums on an insurance contract covering an employee. The plan may hold the contract until the employee dies, or it may distribute or sell the contract to the employee at a specific point, such as when the employee retires.
"The guidance targets specific abuses occurring with Section 412(i) plans", stated Assistant Secretary for Tax Policy Pam Olson. "There are many legitimate Section 412(i) plans, but some push the envelope, claiming tax results for employees and employers that do not reflect the underlying economics of the arrangements." Or, to put it another way, tax deductions are being claimed, in some cases, that the Service does not feel are reasonable given the taxpayer's facts and circumstances.
"Again and again, we've uncovered abusive tax avoidance transactions that game the system to the detriment of those who play by the rules," said IRS Commissioner Mark W. Everson.
The IRS has warned against Section 412(i) defined benefit pension plans, named for the former IRC section governing them. It warned against certain trust arrangements it deems abusive, some of which may be regarded as listed transactions. Falling into that category can result in taxpayers having to disclose such participation under pain of penalties, potentially reaching $100,000 for individuals and $200,000 for other taxpayers. Targets also include some retirement plans.
One reason for the harsh treatment of 412(i) plans is their discrimination in favor of owners and key, highly compensated employees. Also, the IRS does not consider the promised tax relief proportionate to the economic realities of these transactions. In general, IRS auditors divide audited plans into those they consider noncompliant and others they consider abusive. While the alternatives available to the sponsor of a noncompliant plan are problematic, it is frequently an option to keep the plan alive in some form while simultaneously hoping to minimize the financial fallout from penalties.
The sponsor of an abusive plan can expect to be treated more harshly. Although in some situations something can be salvaged, the possibility is definitely on the table of having to treat the plan as if it never existed, which of course triggers the full extent of back taxes, penalties and interest on all contributions that were made, not to mention leaving behind no retirement plan whatsoever. In addition, if the participant did not file Form 8886 and the accountant did not file Form 8918 (to report themselves), they would be fined $200,000.
Lance Wallach, the National Society of Accountants Speaker of the Year, speaks and writes extensively about retirement plans, Circular 230 problems and tax reduction strategies. He speaks at more than 40 conventions annually, writes for over 50 publications and has written numerous best selling AICPA books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Business Hot Spots. Contact him at 516.938.5007 or visit www.vebaplan.com.
The information provided herein is not intended as legal, accounting, financial or any other type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.

Dolan Media Newswires 01/22/2010
Small Business Retirement Plans Fuel Litigation
Small businesses facing audits and potentially huge tax penalties over certain types of retirement plans are filing lawsuits against those who marketed, designed and sold the plans. The 412(i) and 419(e) plans were marketed in the past several years as a way for small business owners to set up retirement or welfare benefits plans while leveraging huge tax savings, but the IRS put them on a list of abusive tax shelters and has more recently focused audits on them.
The penalties for such transactions are extremely high and can pile up quickly - $100,000 per individual and $200,000 per entity per tax year for each failure to disclose the transaction - often exceeding the disallowed taxes.
There are business owners who owe $6,000 in taxes but have been assessed $1.2 million in penalties. The existing cases involve many types of businesses, including doctors' offices, dental practices, grocery store owners, mortgage companies and restaurant owners. Some are trying to negotiate with the IRS. Others are not waiting. A class action has been filed and cases in several states are ongoing. The business owners claim that they were targeted by insurance companies; and their agents to purchase the plans without any disclosure that the IRS viewed the plans as abusive tax shelters. Other defendants include financial advisors who recommended the plans, accountants who failed to fill out required tax forms and law firms that drafted opinion letters legitimizing the plans, which were used as marketing tools.
A 412(i) plan is a form of defined benefit pension plan. A 419(e) plan is a similar type of health and benefits plan. Typically, these were sold to small, privately held businesses with fewer than 20 employees and several million dollars in gross revenues. What distinguished a legitimate plan from the plans at issue were the life insurance policies used to fund them. The employer would make large cash contributions in the form of insurance premiums, deducting the entire amounts. The insurance policy was designed to have a "springing cash value," meaning that for the first 5-7 years it would have a near-zero cash value, and then spring up in value.
Just before it sprung, the owner would purchase the policy from the trust at the low cash value, thus making a tax-free transaction. After the cash value shot up, the owner could take tax-free loans against it. Meanwhile, the insurance agents collected exorbitant commissions on the premiums - 80 to 110 percent of the first year's premium, which could exceed $1 million.
Technically, the IRS's problems with the plans were that the "springing cash" structure disqualified them from being 412(i) plans and that the premiums, which dwarfed any payout to a beneficiary, violated incidental death benefit rules.
Under §6707A of the Internal Revenue Code, once the IRS flags something as an abusive tax shelter, or "listed transaction," penalties are imposed per year for each failure to disclose it. Another allegation is that businesses weren't told that they had to file Form 8886, which discloses a listed transaction.
According to Lance Wallach of Plainview, N.Y. (516-938-****), who testifies as an expert in cases involving the plans, the vast majority of accountants either did not file the forms for their clients or did not fill them out correctly.
Because the IRS did not begin to focus audits on these types of plans until some years after they became listed transactions, the penalties have already stacked up by the time of the audits.
Another reason plaintiffs are going to court is that there are few alternatives - the penalties are not appealable and must be paid before filing an administrative claim for a refund.
The suits allege misrepresentation, fraud and other consumer claims. "In street language, they lied," said Peter Losavio, a plaintiffs' attorney in Baton Rouge, La., who is investigating several cases. So far they have had mixed results. Losavio said that the strength of an individual case would depend on the disclosures made and what the sellers knew or should have known about the risks.
In 2004, the IRS issued notices and revenue rulings indicating that the plans were listed transactions. But plaintiffs' lawyers allege that there were earlier signs that the plans ran afoul of the tax laws, evidenced by the fact that the IRS is auditing plans that existed before 2004.
"Insurance companies were aware this was dancing a tightrope," said William Noll, a tax attorney in Malvern, Pa. "These plans were being scrutinized by the IRS at the same time they were being promoted, but there wasn't any disclosure of the scrutiny to unwitting customers."
A defense attorney, who represents benefits professionals in pending lawsuits, said the main defense is that the plans complied with the regulations at the time and that "nobody can predict the future."
An employee benefits attorney who has settled several cases against insurance companies, said that although the lost tax benefit is not recoverable, other damages include the hefty commissions - which in one of his cases amounted to $860,000 the first year - as well as the costs of handling the audit and filing amended tax returns.
Defying the individualized approach an attorney filed a class action in federal court against four insurance companies claiming that they were aware that since the 1980s the IRS had been calling the policies potentially abusive and that in 2002 the IRS gave lectures calling the plans not just abusive but "criminal." A judge dismissed the case against one of the insurers that sold 412(i) plans.
The court said that the plaintiffs failed to show the statements made by the insurance companies were fraudulent at the time they were made, because IRS statements prior to the revenue rulings indicated that the agency may or may not take the position that the plans were abusive. The attorney, whose suit also names law firm for its opinion letters approving the plans, will appeal the dismissal to the 5th Circuit.
In a case that survived a similar motion to dismiss, a small business owner is suing Hartford Insurance to recover a "seven-figure" sum in penalties and fees paid to the IRS. A trial is expected in August.
Last July, in response to a letter from members of Congress, the IRS put a moratorium on collection of §6707A penalties, but only in cases where the tax benefits were less than $100,000 per year for individuals and $200,000 for entities. That moratorium was recently extended until March 1, 2010.
But tax experts say the audits and penalties continue. "There's a bit of a disconnect between what members of Congress thought they meant by suspending collection and what is happening in practice. Clients are still getting bills and threats of liens," Wallach said.
"Thousands of business owners are being hit with million-dollar-plus fines. ... The audits are continuing and escalating. I just got four calls today," he said. A bill has been introduced in Congress to make the penalties less draconian, but nobody is expecting a magic bullet.
"From what we know, Congress is looking to make the penalties more proportionate to the tax benefit received instead of a fixed amount."

Captive Insurance and Section 79 Scams, 419e and 412i Producing Large IRS fines
Posted on November 5, 2007 by admin
October 11, 2010
By Lance Wallach
Have you ever heard of captive insurance, a 419 welfare benefit plan, a 412i defined benefit insurance plan or a Section 79 scam? You may have a client in one, or be in one yourself and not even know it.
You would learn quickly when the IRS disallows your tax deduction and tries to fine you lots of money. What you are about to read about below may seem impossible in America. The IRS first audits, disallows deductions, and charges interest and penalties for being in one of these abusive plans. You then think you are finished with them.
Soon thereafter, you get fined hundreds of thousand of dollars for not reporting yourself to the IRS. I have been helping successful business owners and professionals with this problem for years. I have authored numerous books for the American Institute of CPAs with chapters on this problem.
I have spoken at many conventions on this topic and argued with a lot of people who didn’t think this would ever happen to them. They purchased products sold primarily by insurance agents from large well known insurance companies like Prudential, Pacific Life, Mass Mutual, Guardian, American General, etc.
The plans had opinion letters from lawyers. The business owner’s accountants signed tax returns taking deductions for these plans with insurance products. Why are the business owners and professionals being fined a huge amount of money by various divisions of the IRS for doing what seemed like a legitimate thing to do? How can something like this happen in America?
When many of the business owners and accountants finally take their heads out of the sand, they are usually put out of business by these fines. Years ago, most successful insurance agents were making big money selling 419 and 412i plans. Now they are selling captive insurance and Section 79 scams to unsuspecting business owners and professionals. Most of the plans were sold to successful business owners as plans with large tax deductions where money would grow tax free until needed, whether in retirement or sooner.
I frequently spoke at national accounting and other conventions talking about the problems with most of these plans. I would be attacked by some attendees who where making large insurance commissions selling the plans. I would try to warn insurance company home office executives, but they too had their heads in the sand because of all the money these plans brought in. Now they look foolish when their depositions in the lawsuits are taken.
Later, the IRS got tough and started fining the unsuspecting business owners and professionals hundreds of thousands a year for not reporting on themselves for being in these plans. The agents and insurance companies would advise not to report to the IRS, “This is a good plan. We have approval.” Not only were the business owners fined under IRS Code 6707A, but the insurance agents were also fined 0,000 for not reporting on themselves. Accountants who signed tax returns are even being fined 0,000 by the IRS.
Then the business owners sue the accountants, insurance agents, etc.
I have been following these scenarios for a long time. In fact, I have been an expert witness in many of these cases, and my side has never lost.

Want to Read
My rating:
1 of 5 stars2 of 5 stars3 of 5 stars4 of 5 stars[ 5 of 5 stars ]
Protecting Clients from Fraud, Incompetence and Scams
by Lance Wallach 5.0 of 5 stars 5.00 · rating details · 2 ratings · 1 review Protect your clients - and yourself - from all kinds of financial chicanery and stupidity with this vital new bookIt doesn't matter if a financial error was made because of malice or ignorance - the end result is that you lose money. Luckily, you don't have to sit idly and take it.""If you have "Protecting Clients from Fraud, Incompetence and Scams," you can identify and avoid the dysfunctional sectors of the financial industry, steer clear of the fallout from the Madoff Era, and guide your clients to real, healthy, sustainable returns.
This powerful book Pinpoints dysfunctional sectors within the financial industry and offers advice against frauds and scammers Shows how a team approach to asset management can ward off financial predators Offers practical strategies and tools to combat client risk for Risk and Asset Management Offering insightful information to protect your clients from all sorts of frauds and incompetence, this essential guide equips you with tips and techniques to spot the red flags of fraud and prevent it before it starts. (less)

Captive Insurance Plans _Dirty Dozen
Thursday, November 17, 2016
CJA and associates 419 412i section 79 scam audits lawsuits Review 300240 Oct 24, New York City, New York, Life Insurance @ Pissed Consumer
CJA and associates 419 412i section 79 scam audits lawsuits Review 300240 Oct 24, New York City, New York, Life Insurance @ Pissed Consumer
Posted by Lance Wallach at 6:19 AM No comments:
Email This BlogThis! Share to Twitter Share to Facebook Share to Pinterest Wednesday, November 16, 2016 Captive Insurance_I told You So_The IRS is Looking For You As I have been warning for the last few years some captive insurance plans are being looked at and audited.
If you are in a captive, which may be legal, you still may have to file under IRS 6707A. Most people who file do it wrong and then you have compounded the problem by lying to the IRS. Make one mistake on the forms and you have another problem. On November 1, 2016, the Internal Revenue Service (“IRS”) issued Notice 2016-66 identifying certain transactions relating to small captive insurance companies as a “transaction of interest.” Prior to this notice, the IRS had identified certain small captives as amongst its list of “Dirty Dozen Tax Scams.” Also, the IRS has been actively examining captives and their owners and litigating cases in the U.S.
Tax Court. The new “transaction of interest” designation throws small captive insurance company transactions into a tax reporting regime that can potentially lead to significant penalties and IRS income tax and promoter examinations. Under section 831(b) of the Internal Revenue Code (the “Code”), so-called small or “micro” captives can elect to exclude from income up to $1.2 million of premiums received ($2.2 million beginning in 2017) and only pay tax on their investment income. Also, the premiums are deducted by the insured as a business expense under section 162 of the Code.
Notice 2016-66 states that small captives have the potential for tax avoidance or evasion and identifies certain small captives, and substantially similar transactions, as a “transaction of interest” in order to gather more information about why and how small captives are being formed and operated. Generally, small captives that constitute a “transaction of interest” are those that (1) have liabilities for covered losses and expenses in an amount less than 70 percent of the total premiums earned, or (2) provide premium payments as financing to an insured or related party in a transaction nontaxable to the recipient (e.g., loans). In either case, the period tested is the most recent 5-year taxable period. Each of the insureds, captives, and any material advisors must report the transaction to the IRS, including the IRS Office of Tax Shelter Analysis.
Taxpayers will have to report the small captive “transaction of interest” annually by filing a Form 8886 with their tax returns beginning with the 2016 tax year, and will have to report separate Forms 8886 for each prior year, some forms due by January 30, 2017. See Treas. Reg. § 1.6011-4(e)(2)(i).
Under section 6707A, each unfiled or late-filed Form 8886 is subject to a penalty in the amount of $50,000 or $10,000 for natural persons. Material advisors must also report the transaction of interest by filing Form 8918 (and are subject to additional list maintenance requirements). Under section 6707, an unfiled or late-filed Form 8918 is subject to a penalty in the amount of $50,000 (and further penalties for failure to timely supply the required list to the IRS upon request). According to the Notice, retroactive reporting is required for described captives that were formed on or after November 2, 2006 (not 2016), which is the date the “transaction of interest” regulations first went into effect.
A material advisor could be the seller, insuarance agent or the accountant who files your tax return, etc. Finally, the Notice requires that transaction participants provide detailed information on the relevant disclosure forms. The disclosure information includes (1) whether liabilities incurred are less than 70 percent of premiums (minus certain dividends and loans); (2) whether any loan or other financing arrangement has occurred between the captive and related parties; (3) the captive’s jurisdiction; (4) a description of the types of coverage(s); (5) how the premium(s) was/were determined, including the names and contact information for any actuary or underwriter involved; (6) a description of the claims paid; and (7) a description of the captive’s assets. This detailed information should not be taken lightly as the IRS can treat an incomplete disclosure as nondisclosure and therefore, subject to penalties.
Lance Wallach Ph.: (516)938-**** Fax: (516)938-**** www.vebaplan.com National Society of Accountants Speaker of The Year The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice. Posted by Lance Wallach at 11:23 AM No comments: Email This BlogThis! Share to Twitter Share to Facebook Share to Pinterest Labels: 831 (b), captive insurance, captive insurance plans, form 8886 Captive Insurance Companies Association ("CICA") The Captive Insurance Companies Association ("CICA"), a trade association representing the captive insurance industry, has issued a statement on section 831(b) companies with cautionary language: The traditional captive insurance company industry and CICA are extremely concerned about the misuse of small captives utilizing the IRC 831(b) election and the attendant publicity about "captives" being a tax avoidance device.
Although there is nothing wrong with the utilization of the 831(b) election when a small captive insurance company is truly engaged in insuring the risk of its parent company/owner(s), the traditional captive insurance industry strongly opposes the utilization of small 831(b) captives primarily for tax sheltering purposes. In simple language, do 831(b)s right or don't do them at all!

Section 79 Plans
Your Best Resource for Section 79 Questions, Problems, Information
516-938-****
You WILL Be Audited For Your Section 79 Plan
Section 79 plans, listed transactions, reportable transactions, 419e, 412i, and captive insurance plans are all targets of IRS Auditors. Do you know the ins and outs of these plans enough to protect yourself or clients?
We do, and we can help you too. You WILL be audited. It's just a matter of when. You need help and you need it now.
Educate yourself here, then call for assistance. Your finances are at risk if you put off dealing with this problem. Call 516-935-**** to speak with an expert today. National Office 516-938-**** Email: section79expert ReportableTransactions ListedTransactions Taxaudit419 Taxlibrary.us Irsform8886 irs6707Apenalty section79expert 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 the rest of the breaking news article here: Large 419 plan files for Bankruptcy 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 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 (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. Plan administrators frustrated with IRS attacks on 412i, 419e plans IRS Auditing 412(i) Plans Our tax resolution offices have received calls regarding the following companies or plans: CJA, CJA and Associates Information You Need to Know Section 79 and captive insurance plans with life insurance in them are being looked at by the IRS. We have received calls from people that are being audited.
- The dangers of being "listed" - A warning for 419, 412i, Sec.79 and captive insurance. Accounting Today: October 25, 2010, By: Lance Wallach Taxpayers who previously adopted 419, 412i, captive insurance or Section 79 plans are in big trouble. To Read More: Offshore International Today Aug 2011 You may want to think about participation in the IRS’ offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS?
Some clients think they are too small to be prosecuted. They are wrong. To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo.
He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That’s it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
“So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs. The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years. Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops.
We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don’t want this to happen to you? Visit taxadvisorexpert.com today!
Copyright (C) 2014 Lance Wallach All rights reserved Most people have never heard of a Section 79 Plan, because it is a wealth building tool pitched by insurance agents who really do not understand the math behind the plan. National Office 516-938-**** Email: section79expert July The Newspaper of the NYSSCPA Vol. 10, No.13 ________________________________________ By Lance Wallach, CLU, ChFC, CIMC, and Ron Snyder, JD, EA Following the U.S. Congress’ lead, on April 10 the IRS issued final regulations under Section 409A of the Internal Revenue Code.
If the rules seemed unclear before, they are crystal clear now: Most of the so-called “419(e)” plans as well as the remaining 419A(f)(6) plans are in violation of the law and subject to hefty penalties.
A 419(e) plan is a benefit plan that generally seeks to make the purchase of life insurance tax-deductible to employers. While the concept is appealing, most of the existing arrangements have permitted the plans to transfer the insurance policies to the participants upon retirement.

419 Insurance Welfare Benefit Plans Continue to Get Accountants in Trouble
________________________________________
February 6, 2012 By Lance Wallach, CLU, CHFC
________________________________________
Popular so-called "419 Insurance Welfare Benefit Plans," sold by most insurance professionals, are getting accountants and their clients into more and more trouble. A CPA who is approached by a client about one of the abusive arrangements and/or situations to be described and discussed in this article must exercise the utmost degree of caution, not only on behalf of the client, but for his/her own good as well.
The National Conference of CPA Practitioners - By Lance Wallach The penalties noted in this article can also be applied to practitioners who prepare and/or sign returns that fail to properly disclose listed transactions, including those discussed herein.
On Oct. 17, 2007, the IRS issued Notice 2007-83, Notice 2007-84, and Revenue Ruling 2007-65. Notice 2007-83 essentially lists the characteristics of welfare benefit plans that the Service regards as listed transactions. Put simply, to be a listed transaction, a plan cannot rely on the union exception set forth in IRC Section 419A(f)(5),there must be cash value life insurance within the plan and excessive tax deductions for life insurance, in excess of what may be permitted by Sections 419 and 419A, must have been claimed.
In Notice 2007-84, the Service expressed concern with plans that provide all or a substantial portion of benefits to owners and/or key and highly compensated employees. The notice identified numerous specific concerns, among them: 1. The granting of loans to participants; 2. Providing deferred compensation; 3.
Plan terminations that result in the distribution of assets rather than being used post-retirement, as originally established; and 4. Permitting the transfer of life insurance policies to participants. Alternative tax treatment may well be in the offing for such arrangements, as the IRS intends to re-characterize such arrangements as dividends, non-qualified deferred compensation (under IRC Section 404(a)(5) or Section 409A), split-dollar life insurance arrangements, or disqualified benefits pursuant to Section 4976. Taxpayers participating in these listed transactions should have, in most cases, already disclosed such participation to the Service.
Those who have not should do so at the earliest possible moment. Failure to disclose can result in severe penalties – up to $100,000 for individuals and $200,000 for corporations. Finally, Revenue Ruling 2007-65 focused on situations where cash value life insurance is purchased on owner employees and other key employees, while only term insurance is offered to the rank and file. These are sold as 419(e), 419A (f)(6), and 419 plans.
Life insurance premiums are not inherently tax deductible and authority must be found in Section 79 to justify such a deduction. Section 264(a), in fact, specifically disallows tax deductions for life insurance, at least in some cases. And moreover, the Service declared, interposition of a trust does not change the nature of the transaction. Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, abusive tax shelters, financial, international tax, and estate planning.
He writes about 412(i), 419, Section79, FBAR and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 50 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Public Radio’s “All Things Considered” and others. Lance has written numerous books including “Protecting Clients from Fraud, Incompetence and Scams,” published by John Wiley and Sons, Bisk Education’s “CPA’s Guide to Life Insurance and Federal Estate and Gift Taxation,” as well as the AICPA best-selling books, including “Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots.” He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@***.com or visit www.taxadvisorexpert.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.

200K Report Update-
419, 412i, Sect 79, Captive Insurance
March 14,2013
Lance Wallach
516-938-**** LANCE WALLACH HELPS IRS Lance Wallach even tries to help the IRS go after the sellers of abusive 419, 412i, captive insurance and section 79 plans. He has also spoken at conventions partially sponsored by the IRS, met with IRS officials at their headquarters in Washington D.C.
and has received phone calls from the IRS on point. Lance Wallach does NOT give the IRS the names of people that RETAIN him to help them. Lance does not give the IRS the names of people that he refers to others for help. To: Itzkowitz Ronald R Subject: Lance Wallach Hope all is well with you.
I never heard from your contact about the abusive shelter information that you sent to him. This stuff on section 79 and captive is not all over the net and is sold by the same promoters that used to sell the 412i and 419 scams?????? Also please see attached two articles that mention section 79 and captives. When I speak at accounting conventions, or write articles about them I am sometimes attacked by promoters of the plans.
The articles are not 100% correct, as the publications sometimes change content without checking with the authors. To: Itzkowitz Ronald R Subject: Re: Lance Wallach AAACPA Thanks and please stay in touch. I hope my published articles were of help to someone at IRS. If you want I will continue to send them as I write them.
From: Itzkowitz Ronald R Sent: Monday, November 28, 2011 3:36 PM To: Havicon Jon S Cc: 'LAWALLACH@***.com' Subject: RE: Lance Wallach Hi, Jon, Would you please follow-up with your contact. Thank, Ron Ronald R. Itzkowitz National EP Customer Partnership Analyst Internal Revenue Service - Employee Plans Lance Wallach From: Ronald.R.Itzkowitz@***.gov To: LAWALLACH@***.com Subj: RE: Lance Wallach AAACPA Happy New Year Mr. Wallach and thanks for the article.
Ron Ronald R. Itzkowitz From: Ronald.R.Itzkowitz@***.gov To: LAWALLACH@***.com Good Morning Mr. Wallach, Here is the reply I got. xxxxxxxxxxxxxxxxxxxx Ronald R.
Itzkowitz Lance Wallach 68 Keswick Lane To: Itzkowitz Ronald R Subject: Re: Lance Wallach AAACPA Thanks and please stay in touch. I hope my published articles were of help to someone at IRS. If you want I will continue to send them as I write them. From: Ronald.R.Itzkowitz@***.gov To: LAWALLACH@***.com Subj: RE: Lance Wallach AAACPA I did pass the articles along, and do continue to send them Ronald.R.Itzkowitz@***.gov CC: LAWALLACH@***.com Subj: RE: Lance Wallach I forwarded this to Pam xxxxxxxxxx, who is an LDC contact.
. From: LAWALLACH@***.com [mailto:LAWALLACH@***.com] Sent: Monday, November 28, 2011 2:01 PM To: Itzkowitz Ronald R Subject: Lance Wallach Hope all is well with you. I xxxxxxxxxxxxxxxxxx. This stuff on section 79 and captive is all over the net and is sold by the same promoters that used to sell the 412i and 419 scams??????
Also please see attached two articles that mention section 79 and captives. xxxxxxxxx

http://section79plan.org
Where can I get Help with Section 79 Plan Problem?
Hello, I'm Lance Wallach...the leading authority in helping
people with Section 79 Plan Problems.
Google "Lance Wallach Section 79" for proof!
For free 15 minute phone consultation call me at: 516-938-**** and make the Section 79 Plan Problem go away

IRS audits 419 plans, IRS raids Benistar, Nova, Grist Mill Trust
________________________________________
April 24, 2012 By Lance Wallach, CLU, CHFC
________________________________________
IRS raided Nova, Benistar, Grist Mill Trust taking records etc. IRS is now auditing this 419 plan. As a result lawsuits against insurance agents, insurance cos. etc are resulting.
419 Life Insurance Plans and Other Scams – Large IRS Fines –
The IRS Raids Plan Promoter Benistar, and What Does All This Mean To You?
October 13,
Recently IRS raided Benistar, which is also known as the Grist Mill Trust, the promoter and operator of one of the better known and more heavily scrutinized of the Section 419 life insurance plans. IRS attacked the Benistar 419 plan, and one of its tactics was to demand the names of all the clients Benistar worked with — so they could be audited by the IRS, Benistar refused to give the names and actually appealed the decision to turn over the names. The appeal was unsuccessful, but Benistar officials still refused to give up the names. Recently, the IRS raided the Benistar office and took hundreds of boxes of information, which included information on clients who were in their 419 plan. In documents filed by Benistar itself, they stated that 35 to 50 armed IRS agents descended upon their office to seize documents.
IRS has visited, and is still visiting most of the other plans and obtaining names of participants, selling insurance agents, accountants, etc. They have a whole task force devoted to auditing 419, 412i and other abusive plans.
It’s important to understand what could happen to unsuspecting business owners if they get involved in plans that are not above board. Their names could be turned over to the IRS, where audits could ensue, and where the outcome could be the payment of back taxes and significant penalties. Then they would be fined another time under Section 6707A for not properly reporting on themselves.
Most 419 life insurance and 412i defined benefit pension plans were sold to successful business owners as plans with large tax deductions where money would grow tax free until needed in retirement. I would speak at national accounting and other conventions talking about the problems with most of these plans. I would be attacked by some attendees who where making large insurance commissions selling the plans. I would try to warn insurance company home office executives, but they too had their heads in the sand because of all the money these plans brought in. Then the IRS got tough and started fining the unsuspecting business owners hundreds of thousands a year for not reporting on themselves for being in the plan. The agents and insurance companies advise against filing. “This is a good plan. We have approval.” Not only were the business owners fined under IRS Code 6707A, but the insurance agents were also fined $100,000 for not reporting on themselves. Accountants who signed tax returns are even being fined 100,000 by IRS. Then the business owners sue the accountants, insurance agents, etc. I have been following these scenarios for a long time. In fact, I have been an expert witness in many of these cases, and my side has never lost.
Most promoters of 419 plans told clients that their plans complied with the laws and, therefore, were not listed tax transactions. Unfortunately, the IRS doesn’t care what a promoter of a tax-avoidance plan says; it makes its own determination and punishes those who don’t comply.
The McGehee Family Clinic, P.A. was recently hit with back taxes and a penalty under Code Sec. 666A in conjunction with a deduction to the Benistar 419 plan
Dr. McGehee's clinic took a deduction for a 419 plan (the Benistar plan) back in 2005. Eventually, the McGhee Family Clinic was audited. After the audit, the doctor was told that the deduction would be disallowed and that back taxes were due. Additionally, Dr. McGehee was hit with a 20 percent accuracy-related penalty under Code Sec. 6662A. Finally, the tax court sustained the IRS's determination that McGehee was subject to the increased 30 percent penalty, because its return did not include a disclosure statement indicating its participation in the Benistar Trust. I think that in addition to the aforementioned fines, IRS will now fine him, both on a corporate and personal level, another $200,000 or more, under IRC 6707A, for not properly disclosing his participation in a listed transaction. There was a moratorium on those fines until June 2010, pending new legislation to reduce them. The fines had been 200,000 per year on the corporate level and $100,000 per year on the personal level. You got the fine even if you made no contributions for the year. All you had to do was to be in the plan. So Dr. McGehee's fine would be a total of $300,000 per year for every year that he and his corporation were in the plan. IRS also says the fine is not appealable. His fine would be in the million-dollar range and it would be in addition to the back taxes, interest, and penalties already discussed earlier in this paragraph.
Legislation just passed slightly reducing those fines, but you still have to properly file to start the Statute of Limitations running to avoid the fines. IRS is fining people who report on themselves, but make a mistake on the forms. Now that the moratorium on the fines has passed, and so has the new legislation, IRS has aggressively moved to fine unsuspecting business owners hundreds of thousands. This is usually after they get audited, and sometimes reach agreement with IRS. Then another division or department of the IRS imposes a fine under 6707A. I am receiving a lot of phone calls from business owners who this is happening to. Unfortunately, some of these people already had called me. I warned them to properly file under 6707A. Either they did not believe me - it is unbelievable - or their accountant or tax attorney filed incorrectly. Then they called again after being fined.
As an expert witness lance wallach has never lost a case cja benistar grist mill turst sadi trust nova trust benistar

TAX MATTERS
TAX BRIEFS
ABUSIVE INSURANCE PLANS GET RED FLAG
The IRS in Notice 2007-83 identified as listed transactions certain trust arrangements involving cash-value life insurance policies. Revenue Ruling 2007-65, issued simultaneously, addressed situations where the tax deduction has been disallowed, in part or in whole, for premiums paid on such cash-value life insurance policies. Also simultaneously issued was Notice 2007-84, which disallows tax deductions and imposes severe penalties for welfare benefit plans that primarily and impermissibly benefit shareholders and highly compensated employees.
Taxpayers participating in these listed transactions must disclose such participation to the Service by January 15. Failure to disclose can result in severe penalties--- up to $100,000 for individuals and $200,000 for corporations.
Ruling 2007-65 aims at situations where cash-value life insurance is purchased on owner/employees and other key employees, while only term insurance is offered to the rank and file. These are sold as 419(e), 419(f) (6), and 419 plans. Other arrangements described by the ruling may also be listed transactions. A business in such an arrangement cannot deduct premiums paid for cash-value life insurance.
A CPA who is approached by a client about one of these arrangements must exercise the utmost degree of caution, and not only on behalf of the client. The severe penalties noted above can also be applied to the preparers of returns that fail to properly disclose listed transactions.
Prepared by Lance Wallach, CLU, ChFC, CIMC, of Plainview, N.Y.,
516-938-****, a writer and speaker on voluntary employee’s beneficiary associations and other employee benefits.
Journal of Accountancy January 2008

google lance wallach for help

412(e)(3) Plans and Annuities
A 412(e)(3) plan is a tax-qualified, defined benefit pension plan that is funded with either annuities or a combination of annuities and life insurance. These sorts of plans are most often funded through annuities, and those annuities have come to be known as 412(e)(3) annuities, because of the section of the Internal Revenue Code that authorizes this sort of plan.
Such 412(e)(3) plans are normally marketed to small businesses as vehicles that can provide large income tax deductions in connection with the establishment or continued funding of a pension plan. The annuities used to fund such a plan often are priced upon low assumed rates of return and other actuarial factors, which means that the employer is required to contribute a larger amount of money up front to fund the plan, and that in turn provides employers with larger tax deductions for their business.
The Lawsuit
The plaintiffs are two small Connecticut businesses that purchased 412(e)(3) annuities from defendant Fidelity Security Life (“FSL”), a Kansas City-based insurance company. Plaintiffs also named as a defendant CJA Associates, Inc., a corporation that is a registered agent of FSL, and is alleged to have promoted the sale of the annuities, and First Actuarial Corporation (“FAC”), a wholly owned subsidiary of CJA that is alleged to have been the sponsor of the plans. In addition, the complaint names an individual who is a registered agent of FSL and is alleged to have served as a tax and investment advisor to the two plaintiff businesses (the complaint also alleges that he was recently indicted by a grand jury for income tax fraud, but does not allege if it was related to his conduct in this case).
All of the non-FSL defendants are alleged to have had some role in the sales process.
Both of the plaintiffs purchased 412(e)(3) annuities from FSL, allegedly as part of the promotional efforts of CJA. Plaintiffs allege that one of the two plaintiffs had their income tax deductions associated with the plans disallowed.
There are no allegations about the tax treatment of the income tax deductions of the second plaintiff, but we assume from that omission that its tax deductions have not been disallowed or challenged.
Plaintiffs contend that the FSL annuities were inappropriate and unsuitable for defined benefit retirement plans for two main reasons. First, plaintiffs contend that the loads used to pay commissions associated with the annuities -- which they claim amounted to 95% of the first year’s contributions and various percentages later on -- were excessive when compared to other annuity products “readily available in the marketplace that achieved the same goals.” The complaint alleges that two other prominent insurance companies were offering comparable yielding annuities with no upfront loads or fees and had their total commissions built into the structure of the product “within the industry standard of 5-6%.” Second, plaintiffs contend that the principal advantage of the product -- its ability to generate large income tax deductions -- was illusory because the employer’s c As an expert witness lance wallach has never lost a case google lance wallach who is all over the net and google your expert who would you pick???

NSA: Member Link
Your link to accounting, tax and practice management ideas, tools, news and information.
Captive Insurance and Other Tax Reduction Strategies – The Good, Bad, and Ugly
By Lance Wallach May 14, 2008
Every accountant knows that increased cash flow and cost savings are critical for businesses in 2008. What is uncertain is the best path to recommend to garner these benefits.
Over the past decade business owners have been overwhelmed by a plethora of choices designed to reduce the cost of providing employee benefits while increasing their own retirement savings. The solutions ranged from traditional pension and profit sharing plans to more advanced strategies.
Some strategies, such as IRS section 419 and 412(i) plans, used life insurance as vehicles to bring about benefits. Unfortunately, the high life insurance commissions (often 90% of the contribution, or more) fostered an environment that led to aggressive and noncompliant plans.
The result has been thousands of audits and an IRS task force seeking out tax shelter promotion. For unknowing clients, the tax consequences are enormous. For their accountant advisors, the liability may be equally extreme.
Recently, there has been an explosion in the marketing of a financial product called Captive Insurance. These so called “Captives” are typically small insurance companies designed to insure the risks of an individual business under IRS code section 831(b). When properly designed, a business can make tax-deductible premium payments to a related-party insurance company. Depending on circumstances, underwriting profits, if any, can be paid out to the owners as dividends, and profits from liquidation of the company may be taxed as capital gains.
While captives can be a great cost saving tool, they also are expensive to build and manage. Also, captives are allowed to garner tax benefits because they operate as real insurance companies. Advisors and business owners who misuse captives or market them as estate planning tools, asset protection vehicles, tax deferral or other benefits not related to the true business purpose of an insurance company face grave regulatory and tax consequences.
A recent concern is the integration of small captives with life insurance policies. Small captives under section 831(b) have no statutory authority to deduct life premiums. Also, if a small captive uses life insurance as an investment, the cash value of the life policy can be taxable at corporate rates, and then will be taxable again when distributed. The consequence of this double taxation is to devastate the efficacy of the life insurance, and it extends serious liability to any accountant who recommends the plan or even signs the tax return of the business that pays premiums to the captive.
The IRS is aware that several large insurance companies are promoting their life insurance policies as investments with small captives. The outcome looks eerily like that of the 419 and 412(i) plans mentioned above.
Remember, if something looks too good to be true, it usually is. There are safe and conservative ways to use captive insurance structures to lower costs and obtain benefits for businesses. And, some types of captive insurance products do have statutory protection for deducting life insurance premiums (although not 831(b) captives). Learning what works and is safe is the first step an accountant should take in helping his or her clients use these powerful, but highly technical insurance tools.
Lance Wallach speaks and writes extensively about VEBAs, retirement plans, and tax reduction strategies. He speaks at more than 70 conventions annually, writes for 50 publications, and was the National Society of Accountants Speaker of the Year. Contact him at 516.938.5007 or visit www.vebaplan.com.
The information provided herein is not intended as legal, accounting, financial or any other type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
National Society of Accountants

Hartford, CT: A consumer fraud class action lawsuit has been filed against Chicago-based CJA and Associates and Kansas City, Missouri-based Fidelity Security Life Insurance Company (FSL).
The lawsuit alleges that CJA and FSL breached fiduciary duties in duping small business owners into investing millions of dollars of employee retirement benefit money in FSL annuities when up to 95% of the initial money invested was being siphoned off in commissions and fees.
The so-called Section 412 (e)(3) plans are under attack from the IRS as illegitimate attempts to avoid federal taxes. The lawsuit alleges that by advising investment in these plans CJA and FSL breached federal laws governing advice given to employee benefit plans.

TAX MATTERS
TAX BRIEFS
ABUSIVE INSURANCE PLANS GET RED FLAG
The IRS in Notice 2007-83 identified as listed transactions certain trust arrangements involving cash-value life insurance policies. Revenue Ruling 2007-65, issued simultaneously, addressed situations where the tax deduction has been disallowed, in part or in whole, for premiums paid on such cash-value life insurance policies. Also simultaneously issued was Notice 2007-84, which disallows tax deductions and imposes severe penalties for welfare benefit plans that primarily and impermissibly benefit shareholders and highly compensated employees.
Taxpayers participating in these listed transactions must disclose such participation to the Service by January 15. Failure to disclose can result in severe penalties--- up to $100,000 for individuals and $200,000 for corporations.
Ruling 2007-65 aims at situations where cash-value life insurance is purchased on owner/employees and other key employees, while only term insurance is offered to the rank and file. These are sold as 419(e), 419(f) (6), and 419 plans. Other arrangements described by the ruling may also be listed transactions. A business in such an arrangement cannot deduct premiums paid for cash-value life insurance.
A CPA who is approached by a client about one of these arrangements must exercise the utmost degree of caution, and not only on behalf of the client. The severe penalties noted above can also be applied to the preparers of returns that fail to properly disclose listed transactions.
Prepared by Lance Wallach, CLU, ChFC, CIMC, of Plainview, N.Y.,
516-938-****, a writer and speaker on voluntary employee’s beneficiary associations and other employee benefits.
Journal of Accountancy January 2008

In a message dated 3/13/2013 12:38:51 P.M. Eastern Daylight Time, LAWALLACH@***.com writes:
Lance Wallach
68 Keswick Lane
Plainview, NY 11803
Ph.: (516)938-****
Fax: (516)938-**** www.vebaplan.com National Society of Accountants Speaker of The Year The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity.
You should contact an appropriate professional for any such advice. -------------------------------------------------------------------------------- From: Ronald.R.Itzkowitz@***.gov To: LAWALLACH@***.com Sent: 7/18/2011 10:13:27 A.M. Eastern Daylight Time Subj: FW: Lance Wallach Good Morning Mr. Wallach, Here is the reply I got.
Ronald R. Itzkowitz National EP Customer Partnership Analyst Internal Revenue Service - Employee Plans Badge Number: 22-06*** * State Street Square 50 West State Street, 12th Floor Trenton, N.J. 08608 Office Phone: (609) 858-**** Office FAX: (609) 858-**** Email: Ronald.R.Itzkowitz@***.gov -------------------------------------------------------------------------------- From: Havicon Jon S Sent: Monday, July 18, 2011 9:47 AM To: Itzkowitz Ronald R Subject: RE: Lance Wallach Not yet. Jon S.
Havicon Internal Revenue Agent 50 W. State Street, 12th Fl Trenton, NJ 08608 (p) 609-858-**** (f) 609-858-**** -------------------------------------------------------------------------------- From: Itzkowitz Ronald R Sent: Monday, July 18, 2011 9:35 AM To: Havicon Jon S Cc: 'LAWALLACH@***.com' Subject: FW: Lance Wallach Jon, Any word on the referral? Ronald R. Itzkowitz National EP Customer Partnership Analyst Internal Revenue Service - Employee Plans Badge Number: 22-06*** * State Street Square 50 West State Street, 12th Floor Trenton, N.J.
08608 Office Phone: (609) 858-**** Office FAX: (609) 858-**** Email: Ronald.R.Itzkowitz@***.gov -------------------------------------------------------------------------------- From: LAWALLACH@***.com [mailto:LAWALLACH@***.com] Sent: Monday, July 18, 2011 9:26 AM To: Itzkowitz Ronald R Subject: Lance Wallach Hope all is well, Have not heard from any of your people yet? Thanks, Lance Wallach 68 Keswick Lane Plainview, NY 11803 Ph.: (516)938-**** Fax: (516)938-****www.vebaplan.com National Society of Accountants Speaker of The Year

. IRS Investigation & Curcio v. Commissioner
The IRS contacted CMI in December 2006, asserting that CMI's contributions to the Benistar 419 Plan were not deductible under § 419A(f)(6), and commenced an investigation. (Snyder Aff. Ex. S.) The scope of the investigation eventually expanded to include Jones's individual tax liability for tax years 2003, 2004, and 2005. (Id. Ex. T; Jones Aff. ¶ 7.) Jones appealed the IRS's determination of his liability for the tax years in question in light of its conclusion that the Benistar 419 Plan did not satisfy the requirements of § 419A(f)(6). (Doc. No. 34 Ex. D.) After several years of investigation, the IRS determined that the contributions to the Benistar 419 Plan were non-deductible deferred compensation and issued Jones a notice of deficiency on July 17, 2009. (Id. Ex. P.)
In 2010, the Tax Court issued its decision in Curcio v. Commissioner, T.C. Memo. 201*-***, 2010 WL 213**** (T.C. 2010). Curcio consolidated "three groups of test cases to resolve a number of disputes regarding companies participating in the Benistar § 419 Plan & Trust." Id. at *2. Carpenter testified over the course of two days as a witness for the taxpayers in Curcio. (See Snyder Aff. Ex. C.) During his testimony, Carpenter stated that Defendants kept a contribution summary that listed details of each employer and the historical account contributions and premium payments, segregated those records, and ensured that plan participants were current with their contributions before paying the policy premiums for that employer. (Id. Ex. C at 71, 260-61.) In the end, the Tax Court found that "although contributions to the plan were deposited in one account, [the Benistar 419 Plan] maintained spreadsheets that allocated every contribution to an employer and a corresponding underlying policy." Curcio, 2010 WL 213****, at *49. Although the Tax Court declined to expressly decide the question, it found all the necessary facts that would support a determination that the Benistar 419 Plan did not meet the strictures of § 419A(f)(6). In light of this, Jones and the IRS reached a settlement shortly after Curcio was decided. He and his wife paid the taxes that the IRS determined he owed and an additional $94,279 in penalties and interest. (Jones Aff. ¶ 7.)
Jones commenced the instant action in the Hennepin County District Court on July 14, 2011, asserting claims of intentional misrepresentation and violations of the Minnesota Consumer Fraud Act, Minn. Stat. § 325F.69, and the Minnesota False Statement in Advertising Act, Minn. Stat. § 325F.67. Defendants removed the action to this Court, and presently before the Court are Defendants' Motions for Sanctions (Doc. No. 13) and Summary Judgment (Docs. No. 19, 21). The issues have been fully briefed, and the Court heard oral argument on July 25, 2012. The Motions are ripe for disposition

Kinsale Insurance Company v. CJA and Associates, Inc.
et al
Defendant: Maurine Hagan, Kent W. Hagan, CJA and Associates, Inc., Hagan & Hagan and Hagan Chiropractic, Inc.
Plaintiff: Kinsale Insurance Company
Case Number: 3:2013cv05303
Filed: November 14, 2013
Court: California Northern District Court Office: San Francisco Office County: XX US, Outside State Presiding Judge: Jacqueline Scott Corley google lance wallach as an expert witness he has never lost a case :grin ,) 8) :p :roll :upset :sigh :sigh

CJA And Associates - PRESIDENT
by Anonymous Jul 05, 2013 6 comments Review #: 426316
1 of 2 Cja And Associates Reviews Next →
Company CJA And Associates
Product / Service Insurance Fraud Negligence
Location Naples, Florida Category Financial Scams and Schemes Views 53 CJA SOLD US DEFECTIVE EMPLOYEE BENEFIT PLANS COSTING US HUNDREDS OF THOUSANDS OF DOLLARS AND IRS AUDITS AND PENALTIES ALL WHILE CJA WALKED AWAY WITH HUNDREDS OF THOUSANDS OF OUR DOLLARS IN COMMISSIONS ALSO THE INSURANCE COMPANY FIDELITY SECURITY LIFE INSURANCE IS PART OF THIS SCHEME TO DEFRAUD COMPANIES OUT OF MILLIONS OF DOLLARS THE IRS GOT LIST OF ALL OF CJA CUSTOMERS AND CAME AFTER THEM WITH AUDITS AND HUGE FINES, CJA HAS DONE NOTHING TO RECTIFY THEIR MISTAKE AND REFUSES TO GIVE BACK ANY MONEY OR ANY OF THE COMMISSIONS THEY TOOK AT THEIR CUSTOMERS EXPENSE AND EXPOSURE TO HUNDREDES OF THOUSANDS OF IRS PENALTIES 183**** :grin :) :eek :upset :upset :zzz :sigh :sigh :sigh :sigh :?

:cry :cry
FAST PITCH NETWORKING
IRS Hiring Agents in Abusive Transactions Group
Posted: Dec. 10, 2010
By Lance Wallach
Here it is. Here is your proof of my predictions. Perhaps you didn’t believe me when I told you the IRS was coming after what it has deemed “abusive transactions,” but here it is, right from the IRS’s own job posting. If you were involved with a 419e, 412i, listed transaction, abusive tax shelter, Section 79, or captive, and you haven’t yet approached an expert for help with your situation, you had better do it now, before the notices start piling up on your desk.
A portion of the exact announcement from the Department of the Treasury:
Job Title: INTERNAL REVENUE AGENT (ABUSIVE TRANSACTIONS GROUP)
Agency: Internal Revenue Service
Open Period: Monday, October 18, 2010 to Monday, November 01, 2010
Sub Agency: Internal Revenue Service
Job Announcement Number: 11PH1-SBB0058-05**-**/13
Who May Be Considered:
• IRS employees on Career or Career Conditional Appointments in the competitive service
• Treasury Office of Chief Counsel employees on Career or Career Conditional Appointments or with prior competitive status
• IRS employees on Term Appointments with potential conversion to a Career or Career Conditional Appointment in the same line of work
According to the job description, the agents of the Abusive Transactions Group will be conducting examinations of individuals, sole proprietorships, small corporations, partnerships and fiduciaries. They will be examining tax returns and will “determine the correct tax liability, and identify situations with potential for understated taxes.”
These agents will work in the Small Business/Self Employed Business Division (SB/SE) which provides examinations for about 7 million small businesses and upwards of 33 million self-employed and supplemental income taxpayers. This group specifically goes after taxpayers who generally have higher incomes than most taxpayers, need to file more tax forms, and generally need to rely more on paid tax preparers.” Their examinations can contain “special audit features or anticipated accounting, tax law, or investigative issues,” and look to make sure that, for example, specialty returns are filed properly.
The fines are severe. Under IRC 6707A, fines are up to $200,000 annually for not properly disclosing participation in a listed transaction. There was a moratorium on those fines until June 2010, pending new legislation to reduce them, but the new law virtually guarantees you will be fined. The fines had been $200,000 per year on the corporate level and $100,000 per year on the personal level. You got the fine even if you made no contributions for the year. All you had to do was to be in the plan and fail to properly disclose your participation.
You can possibly still avoid all this by properly filing form 8886 IMMEDIATELY with the IRS. Time is especially of the essence now. You MUST file before you are assessed the penalty. For months the Service has been holding off on actually collecting from people that they assessed because they did not know what Congress was going to do. But now they do know, so they are going to move aggressively to collection with people they have already assessed. There is no reason not to now. This is especially true because the new legislation still does not provide for a right of appeal or judicial review. The Service is still judge, jury, and executioner. Its word is absolute as far as determining what is a listed transaction.
So you have to file form 8886 fast, but you also have to file it properly. The Service treats forms that are incorrectly filed as if they were never filed. You get fined for filing incorrectly, or for not filing at all. The Statute of Limitations does not begin unless you properly file. That means IRS can come back to get you any time in the future unless you file properly.
If you don’t want these new IRS Agents, or any other IRS agents for that matter, to be earning their paychecks by coming after you, make sure you have done all you can to ensure that you have filed properly by reaching out for expert help today.
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He gives expert witness testimony and his side has never lost a case. Contact him at 516.938.5007, wallachinc@***.com or visit www.taxadvisorexperts.org or www.taxaudit419.com.
The information provided herein is not intended as legal, accounting, financial or any other type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice
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Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : IRS Attacks CJA & CJA and Associates’ plans
Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : IRS Attacks CJA & CJA and Associates’ plans
Posted by Lance Wallach at 3/18/2015 05:38:00 PM
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Share to Twitter Share to Facebook Share to Pinterest Labels: 412i, 419, Abusive Insurance, Abusive Tax Shelters, ance Wallach, IRS, IRS Audits, Life Insurance, litigation, Welfare Benefit Plans 2 comments: Lance WallachMay 13, 2016 at 8:47 AM III. The Insurance Companies The Inter-American Insurance Co.
of Illinois (InterAmerican) specializes in providing to small, closely held corporations products such as qualified pension and profit sharing plans and group life insurance plans. When Inter- - 16 - American was formed in the late 1970’s, it was owned indirectly by Beaven/Inter-American Cos., Inc. (Beaven/Inter-American), the wholly owned company of Raymond G. Ankner (Mr.
Ankner), who has worked in the insurance industry for more than 30 years. InterAmerican liquidated on December 23, 1991, pursuant to a court order to do so, and Beaven/Inter-American changed its name to Beaven Cos., Inc. Mr. Ankner currently markets the life insurance products described herein through a company of his called CJA & Associates.
Reply Lance WallachAugust 22, 2016 at 7:52 AM Class Action Filed against CJA and Associates and Fidelity Security Life Hartford, CT: A consumer fraud class action lawsuit has been filed against Chicago-based CJA and Associates and Kansas City, Missouri-based Fidelity Security Life Insurance Company (FSL). The lawsuit alleges that CJA and FSL breached fiduciary duties in duping small business owners into investing millions of dollars of employee retirement benefit money in FSL annuities when up to 95% of the initial money invested was being siphoned off in commissions and fees.
The so-called Section 412 (e)(3) plans are under attack from the IRS as illegitimate attempts to avoid federal taxes. The lawsuit alleges that by advising investment in these plans CJA and FSL breached federal laws governing advice given to employee benefit plans.
Kinsale Insurance Company v. CJA and Associates, Inc.
et al
Defendant: Maurine Hagan, Kent W. Hagan, CJA and Associates, Inc., Hagan & Hagan and Hagan Chiropractic, Inc.
Plaintiff: Kinsale Insurance Company
Case Number: 3:2013cv05303
Filed: November 14, 2013
Court: California Northern District Court Office: San Francisco Office
Lance Wallach
Lance Wallach
Abusive tax shelters, 419, section 79, 412i micro captive insurance, VEBA, expert witness, author, speaker
DJ@***.GOV writes:
Mr. Wallach,
Thank you for taking the time to speak with xxxx and I this morning.
As we indicated during our telephone call, we may be interested in using you as a consultant in connection with the prosecution of our civil case against Mr Accordingly, we would like to set up a time later this week to discuss this matter with you in more detail. What about Thursday afternoon? Also, we may wish to share documents and other information with you about our case on a confidential basis. In that regard, attached please find our standard confidentiality agreement.
If it is acceptable to you, please sign and return the signed copy to me by email dj@***.gov) Thank you again for expressing an interest in assisting us.
Please call me o Senior Trial Counsel Enforcement Division U.S. Securities and Exchange Commission @***.gov
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For help with CJA & Associates and 412i, 419, and other abusive plans contact Lance Wallach at lawallach@***.com or call 516-938-****. Lance Wallach is the leading expert on 412i, 419, Section 79 and Captive Insurance Plans.
Lance has helped hundreds of people resolve their problems and get all their money back, usually without a lawsuit. Google Lance Wallach and see why CJA & Associates, insurance companies, and the IRS do not want to fight with Lance Wallach.
CLASS ACTION FILED AGAINST CJA AND ASSOCIATES AND FIDELITY SECURITY LIFE
CONTACT US Name: * Email: * Check here to receive email updates Subject: * Message: * Submit Enter text Enter text Enter text LANCE WALLACH EXPERT WITNESS CJA.TAX © COPYRIGHT Class Action Filed against CJA and Associates and Fidelity Security Life Hartford, CT: A consumer fraud class action lawsuit has been filed against Chicago-based CJA and Associates and Kansas City, Missouri-based Fidelity Security Life Insurance Company (FSL). The lawsuit alleges that CJA and FSL breached fiduciary duties in duping small business owners into investing millions of dollars of employee retirement benefit money in FSL annuities when up to 95% of the initial money invested was being siphoned off in commissions and fees.
The so-called Section 412 (e)(3) plans are under attack from the IRS as illegitimate attempts to avoid federal taxes. The lawsuit alleges that by advising investment in these plans CJA and FSL breached federal laws governing advice given to employee benefit plans.
Ray Ankner is truly a shadyn character, fraud, tax evasion, gettin g away with it for decades. Owed mucho $ to our frie d for decades while he was living it up in multiple homes in Naples and Chicago.
Took his time over decades until our friend was i his 90s for this criminal to finally pay him back. It's a woner thgis man hasn't gone to prison for any of his white collar crimes.