Anonymous
map-marker Hicksville, New York

Abusive syndicated conservation easement deals remain a major focus for the IRS. These transactions generally use inflated appraisals of undeveloped land and partnerships devoid of legitimate business

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Abusive syndicated conservation easement deals remain a major focus for the IRS. These transactions generally use inflated appraisals of undeveloped land and partnerships devoid of legitimate business purpose designed to generate inflated and unwarranted tax deductions. "Bogus syndicated conservation easement transactions undermine the public's trust in private land conservation and defraud the government," Rettig said. "Putting an end to these schemes is imperative." Abusive micro-captive insurance arrangements also remain a key focus of IRS enforcement. These deals are generally sold to owners of closely held entities. The deals commonly lack many of the necessary attributes of insurance, have excessive premiums, insure highly improbable risks and have no connection to genuine business and insurance needs.
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Davis Ihd

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INSURANCE EXPERT AND TAX PRACTICE EXPERT AND EXEMPT ORGANIZATIONS AND TAX NOTES TODAY FEDERAL AND TAX NOTES FEDERAL : PRACTICE ARTICLES Abusive Insurance, Welfare Benefit, and Retirement Plans BY LANCE WALLACH|3/2

Davis Ihd
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https://***/pulse/life-insurance-crooks-lance-wallach/

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robett s

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Helped fight IRs

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audited and beat IRS and sued insurance agent who sold scam and got all money back

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Exactly as described/ advertised
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Davis Ihd

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Lance Wallach, is a 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, IRC 6707A, Abusive Tax Shelters, listed transactions, veba plans, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, and 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 AICPA best-selling books.

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Logo HomeNewsAnalysisServicesRegional titlesEventsLinksDirectoryPublicationsNewsletter Signup IRS will not stop the assault on micro-captives 08-07-2021 IRS will not stop the assault on micro-captives Shutterstock/Paul Brady Photography More on this story IRS interpretation of Anti-Injunction Act “tyrannically unconstitutional”: CIC Services 18-05-2021 Other related IRS warns micro captive owners to get out of them as soon as possible 12-04-2021 Micro-captives makes IRS "Dirty Dozen" list for 3rd year running 22-02-2017 Advisers to small captives must declare certain transactions to IRS 21-11-2016 This article was written by Lance Wallach, who offers consultancy services to captive insurers. The captive industry must brace itself for the Internal Revenue Service (IRS) to continue its attacks on the micro-captive, or 831(b) captives industry.

The US needs to raise money and the IRS will be given a lot more resources to audit abusive tax shelters like captives, as well as some conservation easements and cryptocurrencies, as a way of raising it. Hundreds of captive participants have called me for help in recent years, with a variety of different problems and concerns. I served for a period as an expert witness in a case against CIC Services. CIC then went on to beat the IRS in the US Supreme court.

The IRS has every incentive to keep going after micro-captives: in my experience, most disclosure forms are not done properly and the fines are large; and while I like captives, not all small captives follow the law. Last year I met the IRS Commish and some of his assistants, before they stepped up their attacks on small captives. Since then the IRS has increased the number of people on hand to audit small captives. It has also increased the amount of money and training available for captive audits.

The IRS has long viewed micro-captive insurance transactions as potentially abusive tax transactions. Micro-captives first appeared on the IRS “Dirty Dozen” list of tax schemes in 2014 and have been a priority enforcement issue for the IRS ever since. Captives that make an election under section 831(b) are taxed on their investment income and not on their underwriting income or losses. Although many related parties use section 831(b) captive insurance companies for non-tax risk-management purposes, the IRS has a longstanding concern regarding section 831(b) captives, and issued Notice 2016-66 identifying many section 831(b) captives as “transactions of interest.” On April 9, 2021, the IRS issued IR-2021-82, which urged participants in abusive micro-captive insurance arrangements to exit these transactions as soon as possible.

At the time of the release, the IRS noted it has increased examinations of micro-captive arrangements and that it recently won another US Tax Court Case with the March 10, 2021 ruling in Caylor Land & Development versus Commissioner, TC Memo 2021-30 (Caylor).

Do not expect these attacks to stop just because of its setback in the high court with CIC Services. Lance Wallach, Internal Revenue Service, IRS

Guest

great work he is all over the internet and is well know as an expert

Guest
reply icon Replying to comment of Guest-2098002

https://lancewallachexpertwitness.wordpress.com/contact-us/ well known all over the internet as an expert author etc about tax shelters etc.

Guest
reply icon Replying to comment of Guest-2098004

Lance is a well known expert witness and speaker about tax shelter

Guest
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https://lancewallachexpertwitness.wordpress.com/contact-us/

Guest

516236**** fight is

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RICHARD C Exb
map-marker Hicksville, New York

Good help form him

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IRS audited me and I wanted to sue the agent that sold me insurance and told me I could take a tax deduction that was not true. I found Wallach and Lance helped me with everything. I owe my life to him for all his help when no one else could help me.
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fg
map-marker Plainview, New York

Great work

IRS audited and I sued the ins co that sold me a scam wallach as an expert witness won the case
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Guest

he helped me also win a lawsuit i got cheated by insurance and IRS audited he was my expert in a lawsuit and i got my money back this guy was a godsend and helped me a lot the insurance cheat told me to tax deduct the cost and the irs said no and made me pay

Guest

good guy he helped me for free for free can u believe that I don't want my name here but I had a big problem he fixed and I could not afford to pay GOD bless this guy who said one day when I had money I could try to pay him back who does this who???????????????????

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Keya Cjc

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| map-marker New York, New York

Beat insurance company

I baught a 419 plan from an insurance company and IRS audits and got me for lots of money we sued and used lance wallack as an expert witness and the insurance company gave back all my money after they saw his name great news and we are made whole with lance wallace help lance wallack really helped us and now we have our money back again do not buy 419 insurance plan from anyone or this will happen to you thanks God for this man who saved my family and i will recomend him to all that are tricked by insurance people etc.

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Guest

wallach helped me fight the IRS and I won wow

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very nice review

Guest
reply icon Replying to comment of Guest-1658360

https://lancewallachexpertwitness.wordpress.com/contact-us/

Davis Ihd
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https://***/pulse/life-insurance-crooks-lance-wallach/

Guest

nice honest guy wallach

Guest
reply icon Replying to comment of Guest-1645606

hay I know that guy did not help me with work but introduced me to my future husband wow great stuff thanks Lance

Guest

Hes a predator

Guest
reply icon Replying to comment of Guest-1528487

wallach good guy

Guest
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the person did not want to pay

Guest
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sour grapes from a one date lady

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ROSE STABLER

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Lance Wallach took a $10,000. retainer then refused to do any work ...

Wallach was retained as an expert witness in a legal action involving a tax attorney, fraud, and the IRS .

I already lost over $1 million (my home) although i owed no taxes at all. Lance Wallach promised to help , knowing my horrific situation.

When I needed Lance Wallach to help as my expert witness, he refused to do anything at all. I was shocked and asked for some of my money back so I could hire another expert witness.

Wallach refused to refund my money and he would not put any communication in writing regarding my request for his services as promised.

IN SUM. LANCE WALLACH DEFRAUDED ME OF $10,000. AT A LOW POINT IN MY LIFE.

LANCE WALLACH IS A CHARLATAN AND HE IS NOT LICENSED AS A C.P.A. NOR AS A FINANCIAL PROFESSIONAL . I HAVE BEEN UNABLE TO FIND ANY PROFESSIONAL LICENSE WHATSOEVER FOR WALLACH.

HIS RESUME' TURNED OUT TO BE FULL OF LIES.

BEWARE OF THIS PREDATOR!

ROSE STABLER

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Loss:
$10000
38 comments
Guest

she is a golddigger and owed another 12k and did not pay. Google Lance and her who do you trust?

Guest

she is a golddigger and is not being truthful google Wallach and her, who do you believe?

Guest
reply icon Replying to comment of Guest-2097999

https://lancewallachexpertwitness.wordpress.com/contact-us/ she tried to hurt her ex husband and Wallach LANCE would not go along with her plan.

Guest
reply icon Replying to comment of Guest-2098001

her husband was a great football play that she lied about. She never paid her bill and still received lots of help. Look up Lance and her??????

Guest
reply icon Replying to comment of Guest-2097999

golddigger

Guest

MR Wallak helped me fight the internal revenue service who made me pay a lot for life insurance that i was told was a tax deduction this man gave me a name of a guy who beat the IRS and then Wallak helped me get my money back from the insurance co

RICHARD C Exb
reply icon Replying to comment of Guest-1658356

Rose tricked Ken the well know QB and got married to Ken and then took all his money. Where I live they call people like her a golddigger.

Ken was a great guy till he met Rose and anyone who deals with her is sorry.

If this guy did anything to hurt her it is good for her cause she hurt Ken and made him a drug addict etc. Rose will be punished for her bad deeds Look it up what she did to ken

Guest

Hay that Rose is a golddigger her husband was that great quarterback, Wallach probably helped him beat goldigger Rose who cheated her ex husband in my opinion

Guest
reply icon Replying to comment of Guest-1657783

that old bitter lady married Ken the great qb for his money and then divorced google lance wallach and google rose who do u believe wallach is all over the net for helping people rose divorces people for money and said her husband was a drug user etc she only out for money and I do not believe her

Guest

Wallach helped me and sent me to a guy who beat the *** IRS and they tried to get me to pay over 200k I paid 3000 that's it but the guy charged me 5000 o k caused I saved a lot and got those *** off my back

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Robert B Fbl
map-marker New York, New York

Had tax problems Lance Wallach fixed

I had some troubles with listed transactions.

It was a few years ago. And I was sold some different products that were horrible because I was hit with abusive transactions through the IRS and was facing some stiff penalties.

Enter LANCE WALLACH. I contacted him after seeing his information posted on the internet. I didn't know if I could trust what he promised but I was facing such heavy fines, it seemed I needed to try.

Thank goodness for Lance Wallach. Will maybe write more at another time, but for now, just a thanks to Lance for getting me out of some really bad situations.

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Davis Ihd

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Rupert Murdock pays workers 10 an hour

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wallach did great work for me tracy fulbrok

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reply icon Replying to comment of Guest-1645605

Wallach helped me with IRS they wanted to get me for a lot of money wallach gave me the names of some former IRS agents and one helped me beat IRS and I only paid 5k instead of 295k what a difference I think these guys were great and really helped. I dont live in his state he helped on the phone

Guest

Lance Wallach Life Insurance

Wednesday, February 5, 2014

Life Insurance Claims Denial Information - Lawyers Handling Life Insurance Benefits Lawsuits Offer No-Cost, No-Obligation Denial of Death Benefits Case Review

Life Insurance Benefits Lawsuit

Major news sources throughout the United States report that insurance providers are issuing life insurance benefits denials more than ever before. Learning that a life insurance policy is null and void or being denied death benefits after the death of a loved one compounds the emotional trauma of losing a spouse or family member in an already trying time.

Unexpected news of a life insurance claim denial leaves many individuals in a state of economic distress. Spouses and family members who received a letter denying a life insurance claim learn all too late that they lack the financial security their loved one had intended. While the economy struggles in the United States and around the world, many insurance companies report record profits.

When buying into a life insurance policy, Americans believe they are making a prudent choice to provide for loved ones after their own death. In the application process, candidates for life insurance are warned that inaccurate or incomplete answers can negate their life insurance policy.

Major news stories have reported on a trend of life insurance benefits denials that are invalid. “Since 2008, federal judges have concluded that some insurers cheated survivors by twisting facts, fabricating excuses and ignoring autopsy findings in withholding death benefits,” notes an article inBloomberg Markets Magazine.

Increasingly, the article says, insurance companies are citing controversial or even false reasons to deny death benefits claims. The article describes cases of people who were denied life insurance benefits by MetLife and Prudential based on unsubstantiated claims of suicide or failure to report nonexistent details of their past

Guest

that the IRS issued guidance on 412(i) plans in 2004, and has reviewed many of those plans to see if they exceed rules on maximum total benefits, maximum deductions on tax returns and the percentage of a pension plan's assets that can be in life insurance.

ERISA Pension Plans advises businesses on establishing and maintaining pension plans and also advises pension funds.

Guest

lance wallachis the best go on the net and see for yourself he can help in many matters and writes books for the aicpa and others and teaches for lawline

Guest

google lance and goole the other person lol

Guest

Sept 2011

By Lance Wallach

Announced February 8, 2011, the IRS 2011 Offshore Voluntary Disclosure Initiative (OVDI) program is a welcome but conditional amnesty allowing taxpayers with foreign accounts to come clean and get into compliance with the IRS. The program ran through Sept. 9, 2011.

There’s been discussion of “opting out” of the program to take your chances in audit, but it’s a topic fraught with danger. Now, however, there is guidance about opting out of the program that makes much of it transparent. Because of this late date it was recommended that you properly file FBARs and the 90-day request for amnesty extension. This is the first important step. If the forms are not done properly, you will have extensive problems and will not have to think about opting out. If your forms are properly done and filed, then your situation should be discussed with someone who is experienced in these matters.Under the OVDI, taxpayers are subject to a penalty of 25 percent of the highest aggregate account balance on their undisclosed account(s) between 2003 and 2010. If the value was less than $75,000 at all times during those years, the penalty is only 12.5 percent.

These account balance penalties are in lieu of all other penalties that may apply, including FBAR and offshore-related information return penalties. Plus, participants are required to pay taxes and interest on any monies (such as interest income on foreign accounts) they previously failed to report. Finally, they must pay an accuracy-related penalty equal to 20 percent of the underpayment of tax, plus interest.

Opting out of the program can make sense for some, though it involves taking your chances with an IRS examination. Someone should represent you with extensive experience in this. We always suggest they should at least be a CPA with years of experience in international tax. It’s even better if you use one that was with the international tax division of the IRS for a number of years. The IRS has published a separate guide detailing the rules and procedures for opting out.

Here are some of the rules:

1. IRS Summary. The IRS employee who has been handling your case summarizes it, agreeing or disagreeing with your view of penalties, and listing how extensive an audit he or she recommends.

2. Program Status Report. Before you can opt out, the IRS sends a letter reporting on the status of your disclosure and what you still must submit. If you’ve given enough data, the IRS will calculate what you would owe under the OVDI. You should provide any missing items within 30 days.

3. Taxpayer Submission. Within 20 days, the taxpayer opts out in writing and makes a written case what penalties should apply and why.

4. Central Committee. A Committee of IRS Managers reviews the summary and decides how extensive an audit to conduct. The IRS says “the taxpayer is not to be punished (or rewarded) for opting out.” The Committee also decides whether to assign your case for a normal civil audit or to assign it for a criminal exam.

5. Written Warning. The IRS sends another letter explaining that opting out must be in writing and is irrevocable. You have 20 days thereafter to opt out in writing.

6. Interview? Some audits will include taxpayer interviews.

Bottom Line? The “opt out” procedure is helpful but still a bit daunting. If you are considering it, make sure you get some solid advice from an experienced person who, in my opinion, should have worked for the IRS and is a CPA about the nature of your case. This is just one of the many options that should be discussed with your advisor. There are many other strategies that you may want to utilize. Your advisor should be aware of all your options, and should explain them. If not, consider engaging someone else. Remember, the penalties can be very large, especially if your advisor is not skilled at this. There is even the potential for criminal prosecution.

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 over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic 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.

Cherron Qlr

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

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Tax Expert Talks

New Tax Season: What Are The Key Changes?

Feb 12, 2021

How to file your taxes? What tax software to use? What’s changed in the tax law? To help you prepare for tax filing season, Pissed Consumer interviewed Jerry Zeigler. Watch his expert tips on tax preparation. Find out how to avoid tax filing mistakes, tax scams, and make the most value of your returns.

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Jerry Zeigler is an AFC, an Enrolled Agent, and SaverLife financial coach. He has been in the tax field since 2011.

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