Wednesday, December 17, 2014

Insurance Expert Witness

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    Lance Wallach


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    419PROBLEMS.COM
    LANCE WALLACH 419 LITIGATION CONSULTING
    IRS HIRING AGENTS IN ABUSIVE TRANSACTIONS GROUP_LANCE WALLACH
    Here it is. Here is 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 website: “If you or your clients were involved with a 419, and you haven’t yet approached an expert for help, you had better do it now, before the notices start piling up on your desk.” Specific forms need to be properly filed under IRC Section 6707A to avoid large IRS fines. These fines are in addition to IRS audits and disallowances of tax deductions. With this tactic, the IRS gets your client twice. First, they get audited and their tax deduction gets disallowed with possible interest and penalties. Then the IRS comes after your client again for not properly filing forms under Internal Revenue Code 6707A. The resulting fines for not properly filing are large, but they can usually be avoided by properly filing the required forms. Here is a small portion of the job posting I referred to above: Job Title: Internal Revenue Agent (Abusive Transactions Group) Agency: Internal Revenue Service Open Period: Monday, October 18, 2010, to Monday, November 1, 2010Sub Agency: Internal Revenue Service Job Announcement Number: 11PH1-SBB0058-0512-12/13 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; and• 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 proprietor-ships, small corporations, partner-ships 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 conducts examinations for about 7 million small businesses, and upwards of 33 million self-employed and supple-mental income taxpayers. This group specifically goes after taxpayers who generally have higher incomes than most taxpayers, need to file more tax forms and 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.
    TITLE
    MASSACHUSETTS SOCIETY OF CPA'S



    ​The fines are severe. Under IRC 6707A, fines were up to $200,000 annually for not properly disclosing participation in a listed transaction. There was a

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