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TESTIMONIALS FROM SATISFIED CLIENTS:
Letter to Lance Wallach from Ford Motor benefits representative:
Fri, 11 Jan 2008
Dear Mr. Wallach,
It as a pleasure speaking with you this afternoon. I appreciate the time you spent
listening and the giving of your advice.
Next week, we, a small splinter union (IAM) within a large Ford Motor facility, at
Cleveland Casting Plant will be negotiating our contract. This site is mostly represented
by the UAW who have already consummated their contract with Ford Motor Company,
and has accepted the VEBA option for their retirees. Their VEBA will be run by the
UAW and whoever they decide to confide in to execute the health care benefit and the
investments with the millions that Ford Motor will hand over to them, and then Ford will
wash their hands of any more health care responsibilities.
Our IAM negotiations start Jan. 14th. The small group of individuals that will be across
the table from the experts representing Ford Motor, are comprised of a few elected
people that are Pattern Maker/Machinist by trade. We have no one of any particular
expertise in finance, healthcare, or investment. We are expected to come to terms with
little, to no knowledge or leverage of the task set before us. We have 1300 people's
lives that will be affected by these negotiations. It is a shame that the larger unions will
not step up to the plate and help with the terms that we are faced with. Ford Motor will
use this to their advantage to squeeze a few more dollars out of our pockets.
Thank you again for your generous contribution of foresight and knowledge to the
concerns facing the American workers in this globalistic battle for the bottom line.
Mark A. Gwynn
IAM Benefits Rep.
Cleveland Casting Plant
Sep 18, 2007
Subject: Re: VEBA education
Thank you so much. I will read this material and if I have any questions I will call. I do
have one very important question that comes to mind - Have you ever seen a VEBA
go bad and if so, how could it have been prevented? I know like some mutual funds
do not last and if this program is based on investment, there is a very real possibility
that the funds could loose significant amounts. Is there a safe guard to this problem?
U.A.W. Communication Coordinator
U.A.W. Local 2164
712 Plum Springs Loop
Bowling Green, KY 42101
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"Mr. Wallach, thanks so much
for taking the time to talk to
me today about VEBAs. Any
information you can send me
would be helpful. Hopefully,
we can work together in the
future as interest in VEBAs
Corman G. Franklin
Office of the Assistant
Secretary for Policy
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“abusive tax shelter help” "tax letter" "irs letter" "irs letters" "irs determination letter" 419e 412i 6707a "form 8886" "listed transactions" "abusive
tax shelter assistance" "irs penalty abatement" "expert witness irs" veba "expert witness services" "expert witness irs help" "pension audit"
“abusive tax shelter help” “abusive tax shelter assistance” "Grist Mill Trust" Benistar "SADI Trust" "Beta 419" "Millennium Plan" Bisys "Creative
Services Group" "Sterling Benefit Plan" "Compass 419" Niche "Sea Nine Veba" 419 412i 419e "expert witness insurance" "welfare benefit plans"
"419 plan help" "expert witness irs"
IRS Audits 419, 412i, Captive Insurance Plans With Life
Insurance, and Section 79 Scams
Article Biz June 2011
The IRS started auditing 419 plans in the ‘90s, and then continued going after
412i and other plans that they considered abusive, listed, or reportable
transactions. Listed designated as listed in published IRS material available to
the general public or transactions that are substantially similar to the specific
listed transactions. A reportable transaction is defined simply as one that has
the potential for tax avoidance or evasion.
In a recent Tax Court Case, Curcio v. Commissioner (TC Memo 2010-15), the
Tax Court ruled that an investment in an employee welfare benefit plan
marketed under the name "Benistar" was a listed transaction in that the
transaction in question was substantially similar to the transaction described
in IRS Notice 95-34. A subsequent case, McGehee Family Clinic, largely
followed Curcio, though it was technically decided on other grounds. The
parties stipulated to be bound by Curcio on the issue of whether the amounts
paid by McGehee in connection with the Benistar 419 Plan and Trust were
deductible. Curcio did not appear to have been decided yet at the time
McGehee was argued. The McGehee opinion (Case No. 10-102) (United
States Tax Court, September 15, 2010) does contain an exhaustive analysis
and discussion of virtually all of the relevant issues.
Taxpayers and their representatives should be aware that the Service has
disallowed deductions for contributions to these arrangements. The IRS is
cracking down on small business owners who participate in tax reduction
insurance plans and the brokers who sold them. Some of these plans include
defined benefit retirement plans, IRAs, or even 401(k) plans with life
In order to fully grasp the severity of the situation, one must have an
understanding of Notice 95-34, which was issued in response to trust
arrangements sold to companies that were designed to provide deductible
benefits such as life insurance, disability and severance pay benefits. The
promoters of these arrangements claimed that all employer contributions were
tax-deductible when paid, by relying on the 10-or-more-employer exemption
from the IRC § 419 limits. It was claimed that permissible tax deductions were
unlimited in amount.
In general, contributions to a welfare benefit fund are not fully deductible
when paid. Sections 419 and 419A impose strict limits on the amount of tax-
deductible prefunding permitted for contributions to a welfare benefit fund.
Section 419A(F)(6) provides an exemption from Section 419 and Section
419A for certain "10-or-more employers" welfare benefit funds. In general, for
this exemption to apply, the fund must have more than one contributing
employer, of which no single employer can contribute more than 10% of the
total contributions, and the plan must not be experience-rated with respect to
According to the Notice, these arrangements typically involve an investment in
variable life or universal life insurance contracts on the lives of the covered
employees. The problem is that the employer contributions are large relative
to the cost of the amount of term insurance that would be required to provide
the death benefits under the arrangement, and the trust administrator may
obtain cash to pay benefits other than death benefits, by such means as
cashing in or withdrawing the cash value of the insurance policies. The plans
are also often designed so that a particular employer’s contributions or its
employees’ benefits may be determined in a way that insulates the employer
to a significant extent from the experience of other subscribing employers. In
general, the contributions and claimed tax deductions tend to be
disproportionate to the economic realities of the arrangements.
Benistar advertised that enrollees should expect to obtain the same type of
tax benefits as listed in the transaction described in Notice 95-34. The
benefits of enrollment listed in its advertising packet included:
Virtually unlimited deductions for the employer;
Contributions could vary from year to year;
Benefits could be provided to one or more key executives on a selective basis;
No need to provide benefits to rank-and-file employees;
Contributions to the plan were not limited by qualified plan rules and would not
interfere with pension, profit sharing or 401(k) plans;
Funds inside the plan would accumulate tax-free;
Beneficiaries could receive death proceeds free of both income tax and estate
The program could be arranged for tax-free distribution at a later date;
Funds in the plan were secure from the hands of creditors.
The Court said that the Benistar Plan was factually similar to the plans
described in Notice 95-34 at all relevant times.
In rendering its decision the court heavily cited Curcio, in which the court also
ruled in favor of the IRS. As noted in Curcio, the insurance policies,
overwhelmingly variable or universal life policies, required large contributions
relative to the cost of the amount of term insurance that would be required to
provide the death benefits under the arrangement. The Benistar Plan owned
the insurance contracts.
Following Curcio, as the parties had stipulated, on the question of the
amnesty paid by Mcghee in connection with benistar, the Court held that the
contributions to Benistar were not deductible under section 162(a) because
participants could receive the value reflected in the underlying insurance
policies purchased by Benistar—despite the payment of benefits by Benistar
seeming to be contingent upon an unanticipated event (the death of the
insured while employed). As long as plan participants were willing to abide by
Benistar’s distribution policies, there was no reason ever to forfeit a policy to
the plan. In fact, in estimating life insurance rates, the taxpayers’ expert in
Curcio assumed that there would be no forfeitures, even though he admitted
that an insurance company would generally assume a reasonable rate of
The McGehee Family Clinic had 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. The IRS also assessed tax deficiencies and the enhanced 30%
penalty totaling almost $21,000 against the clinic and $21,000 against the
Prossers. The court ruled that the Prossers failed to prove a reasonable
cause or good faith exception.
More you should know:
In recent years, some section 412(i) plans have been funded with life
insurance using face amounts in excess of the maximum death benefit a
qualified plan is permitted to pay. Ideally, the plan should limit the proceeds
that can be paid as a death benefit in the event of a participant’s death.
Excess amounts would revert to the plan. Effective February 13, 2004, the
purchase of excessive life insurance in any plan makes the plan a listed
transaction if the face amount of the insurance exceeds the amount that can
be issued by $100,000 or more and the employer has deducted the premiums
for the insurance.
A 412(i) plan in and of itself is not a listed transaction; however, the IRS has a
task force auditing 412i plans.
An employer has not engaged in a listed transaction simply because it is in a
Just because a 412(i) plan was audited and sanctioned for certain items, does
not necessarily mean the plan is a listed transaction. Some 412(i) plans have
been audited and sanctioned for issues not related to listed transactions.
Companies should carefully evaluate proposed investments in plans such as
the Benistar Plan. The claimed deductions will not be available, and penalties
will be assessed for lack of disclosure if the investment is similar to the
investments described in Notice 95-34. In addition, under IRC 6707A, IRS
fines participants a large amount of money for not properly disclosing their
participation in listed or reportable or similar transactions; an issue that was
not before the Tax Court in either Curcio or McGehee. The disclosure needs
to be made for every year the participant is in a plan. The forms need to be
properly filed even for years that no contributions are made. I have received
numerous calls from participants who did disclose and still got fined because
the forms were not prepared properly. A plan administrator told me that he
assisted hundreds of his participants file forms, and they still all received very
large IRS fines for not properly filling in the forms.
IRS has been attacking all 419 welfare benefit plans, many 412i retirement
plans, captive insurance plans with life insurance in them, and Section 79
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, firstname.lastname@example.org or
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.
Massachusetts Society of Certified Public Accounts, Inc.
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.
"Many taxpayers who are no longer taking current tax deductions for these plans continue to enjoy the
benefit of previous tax deductions by continuing the deferral of income from contributions and
deductions taken in prior years."
Many business owners adopted 412i, 419, captive insurance and Section 79 plans based upon
representations provided by insurance professionals that the plans were legitimate plans and were not
informed that they were engaging in a listed transaction. Upon audit, these taxpayers were shocked
when the IRS asserted penalties under Section 6707A of the Code in the hundreds of thousands of
dollars. Numerous complaints from these taxpayers caused Congress to impose a moratorium on
assessment of Section 6707A penalties.
The moratorium on IRS fines expired on June 1, 2010. The IRS immediately started sending out
notices proposing the imposition of Section 6707A penalties along with requests for lengthy
extensions of the Statute of Limitations for the purpose of assessing tax. Many of these taxpayers
stopped taking deductions for contributions to these plans years ago, and are confused and upset by
the IRS’s inquiry, especially when the taxpayer had previously reached a monetary settlement with the
IRS regarding its deductions. Logic and common sense dictate that a penalty should not apply if the
taxpayer no longer benefits from the arrangement. Treas. Reg. Sec. 1.6011-4(c)(3)(i) provides that a
taxpayer has participated in a listed transaction if the taxpayer’s tax return reflects tax consequences
or a tax strategy described in the published guidance identifying the transaction as a listed transaction
or a transaction that is the same or substantially similar to a listed transaction.
Clearly, the primary benefit in the participation of these plans is the large tax deduction generated by
such participation. Many taxpayers who are no longer taking current tax deductions for these plans
continue to enjoy the benefit of previous tax deductions by continuing the deferral of income from
contributions and deductions taken in prior years. While the regulations do not expand on what
constitutes “reflecting the tax consequences of the strategy,” it could be argued that continued benefit
from a tax deferral for a previous tax deduction is within the contemplation of a “tax consequence” of
the plan strategy. Also, many taxpayers who no longer make contributions or claim tax deductions
continue to pay administrative fees. Sometimes, money is taken from the plan to pay premiums to
keep life insurance policies in force. In these ways, it could be argued that these taxpayers are still
“contributing,” and thus still must file Form 8886.
It is clear that the extent to which a taxpayer benefits from the transaction depends on the purpose of
a particular transaction as described in the published guidance that caused such transaction to be a
listed transaction. Revenue Ruling 2004-20, which classifies 419(e) transactions, appears to be
concerned with the employer’s contribution/deduction amount rather than the continued deferral of
the income in previous years. Another important issue is that the IRS has called CPAs material
advisors if they signed tax returns containing the plan, and got paid a certain amount of money for tax
advice on the plan. The fine is $100,000 for the CPA, or $200,000 if the CPA is incorporated. To
avoid the fine, the CPA has to properly file Form 8918.
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA
faculty of teaching professionals, Wallach is a frequent speaker on retirement plans, financial and
estate planning, and abusive tax shelters. He is also a featured writer and has been interviewed on
television and financial talk shows including NBC, National Pubic Radio’s All Things Considered and
others. Lance authored 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 including Avoiding Circular 230 Malpractice Traps and Common
Abusive Small Business Hot Spots.
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
Contact him at:
US health insurance trusts
As their finances deteriorated, Detroit’s automakers earned the moniker “HMOs on
wheels” for crippling employee healthcare liabilities (Health Maintenance Organizations
are a type of insurer). This was worrisome not only for the companies but also some
850,000 active and retired beneficiaries who feared, with justification, that carmakers
might one day go bust and shed these liabilities. That spurred the United Auto Workers
union to agree in 2007 to Voluntary Employee Beneficiary Associations (VEBA) to
absorb these liabilities. When the trusts were originally negotiated, the carmakers
pledged cash contributions of nearly $60bn, somewhat less than their actual healthcare
liabilities. As the crisis hit, they supplanted promised payments with their own equity
The UAW had little choice, but this partly defeated the purpose of creating the trusts. Not
surprisingly, the trusts have tried to diversify quickly, most recently accepting around
$4bn in cash from Ford, a slight discount for notes receivable, after redeeming stock
warrants for $1.8bn earlier this year. General Motor’s retirees’ healthcare is backed by
$13bn in cash plus $9bn in GM liabilities and up to a fifth of the automakers’ equity. That
could fetch an additional $10bn once a public market exists. Chrysler’s employees are
most exposed with only $2bn in cash plus $4.6bn in notes and up to 68 per cent of
illiquid shares in Detroit’s weakest carmaker. Expert Witness Lance Wallach reckons
these assets can never cover an estimated 80 years of full benefits.
But, by shedding exposure to Detroit and giving themselves the option of trimming
benefits to conserve assets, UAW trustees are effectively creating a less-risky defined
contribution plan. Beneficiaries may squeal, but something is better than nothing.
America’s car industry might have fared better if only unions had let carmakers manage
their liabilities with similar flexibility.
|Copyright (C) 2015 Lance Wallach
All rights reserved
Published by John Wiley & Sons
According to the I.R.S., VEBA is an acronym for "voluntary employees'
beneficiary association." They are trusts that are exempt from tax under
the provisions of IRC section 501(c)(9). A VEBA is a "welfare benefit fund"
to which sections 419 and 419A will apply if it is part of a plan of an
employer through which the employer provides welfare benefits to
employees and their beneficiaries. While welfare benefit funds can also
be taxable trusts, most welfare benefit funds apply for exempt status as
VEBAs in order to reduce or eliminate income taxes at the trust level.
VEBA’s file Form 990, whereas taxable trusts file Form 1041.
A "welfare benefit" is an employee benefit other than those to which IRC
sections 83(h), 404, and 404A apply. The most common types of welfare
benefits are medical, dental, disability, severance and life insurance
Properly structured VEBAs can therefore serve as tax-favored funding
vehicles for many of the foreseeable expenditures (benefits obligations) a
business owner is likely to incur.
Other Post-Employment Benefits
In 1994, the Government Accounting Standards Board (GASB)
established standards for public employee pension plans. Government
and public employers have to report and account for pension benefits
costs. However, until recent years, there was no such standard in place
for other post-employment benefits (OPEBs) for state and local
government workers. Private sector employers have been required to
report OPEBs for over 15 years under the FASB Standards106/158.
Government and public sector employers have been required to report
OPEBs since August 2004 after the issuance of GASB Statement 45.
This means that all government employers must now keep their promise
of providing retiree benefits. They need to be calculated accurately,
accrued during the employee’s years of work with the employer, and
recognized as a financial obligation as OPEB costs. These costs are to
be reported on financial statements of large public sector employers
beginning with the first financial report period after December 15, 2006,
and on small employers beginning in 2008.
The intent of GASB 45 was to bring government and public accounting
standards into line with private company standards. This requires
reporting pensions as well as non-pension post-employment benefits.
As the name states, OPEBs are benefits other than pensions. Many state
and local governments, public schools, public universities and other
public and government agencies provide post-employment benefits that
are non-pension-related. These benefits can include health care benefits
including vision, dental, prescription and health insurance; life insurance;
legal benefits and other non-pension-related work benefits.
Until these changes were put in place with GASB 45 and enforced,
readers of government and public financial statements had incomplete
information on the costs of services provided by state and local
governments and public employers, and were therefore unable to analyze
the financial position and long-term health of these government and
Actuarial calculations are used to derive the OPEB cost. In order to keep
the calculations up to date, they must be recalculated every two to three
years depending on the size of the employer. For example, employers
with less than 100 employees can use a simplified alternative method for
measuring the OPEB cost, but these employers still need to re-evaluate
and re-assess every three years. The costs and obligations for post-
employment benefits are determined using the actuarial present value of
the post-employment benefits - in other words, the present value on term
of service and the terms of the OPEB plan that are presently in place.
Assumptions that are made in the actuarial evaluations include:
§ Healthcare cost factors: age, industry, family, geography, gender.
§ Expected long-term and/or short term rate of return on plan assets.
§ Projected salary scale.
§ Death rates.
§ Projected inflation of medical care costs.
§ Employee turnover rate.
§ Retirement rates; this can vary extensively from year to year.
§ Any promises made to retirees.
§ Discounts or benefits designed into the plan.
After the actuarial evaluations are completed, each employee gains a
different attribution period, which is based on their period of eligibility –
date of hire to date of full eligibility (i.e. retirement). With all this said,
GASB only requires that employers report OPEBs; employers are not
required or even obligated to fund the OPEB cost. However, not doing so
can affect significantly an employer’s credit rating and cost of issuing debt
The largest OPEB cost for an employer is health care benefits. The
majority of public sector employers, with more than 200 employees, offer
some form of post-employment health benefits. Unfortunately, with the
uncontrollable increases in health care costs happening annually, and
severe budget cuts being put in place across nearly all public and
government agencies, the continuing use of “pay-as-you-go” will become
more difficult and create new financial liabilities for employers. Add to this
state laws that require employers to allow retirees to remain on the active
health plan until Medicare steps in, and the reduction in federal and state
subsidies, and employers are struggling to subsidize the gap between
the blended plan cost (active employees and retirees) and the actual
retiree cost. Even if the employer is not contributing to the retiree health
care plan, this amount adds additional liability.
In December 2004, a report from Standard and Poor’s, stated that: “The
new [GASB 45] reporting may reveal cases in which the actuarial funding
of post-employment health benefits would seriously strain operations, or,
further, may uncover conditions under which employers are unable or
unwilling to fulfill these obligations. In such cases, these liabilities may
adversely affect the employer's creditworthiness. All Standard & Poor's
rated employers will be monitored closely in terms of their reporting under
GASB 45. Upon implementation of these new standards, we will include
the new information as part of our ongoing analytical surveillance of
The following year, in June 2005, Fitch Ratings released its report, saying:
“Fitch's credit focus will be on understanding each issuer's [GASB 45]
liability and its plans for addressing it. Fitch also will review an entity's
reasoning for developing its plan. An absence of action taken to fund
OPEB liabilities or otherwise manage them will be viewed as a negative
rating factor. Steady progress toward reaching the actuarially determined
annual contribution level will be critical to sound credit quality."
Everyone is working towards a solution that will benefit both employers
and employees, but it takes constant monitoring by both employers and
employees. However, one solution merits consideration from everyone is
implementing a VEBA plan.
VEBA Plan Benefits
VEBAs have been successfully established to help reduce health costs
and establish financially sound OPEB plans that have proven to be both
efficient and effective. The VEBA can help employers develop strategies
that can lower their liabilities. Many private sector employers have
benefited from the introduction and use of a VEBA for their OPEB plan.
A well designed GASB 45 OPEB involves many different risk management
strategies and funding techniques. Any benefit promise made by an
employer should be partially or fully funded in a qualified trust to enable
actuaries the use of long-term discount rates during the calculations.
One approach to this funding source could be issuing OPEB obligation
bonds or finance pools. The employer can then successfully take these
finance strategies and blend a defined-benefit approach with a defined-
contribution strategy to create a successfully managed OPEB plan with
reduced liabilities. These two basic forms of post-employment benefit
plans specify either the amount of benefits to be provided to an employee
at the end of their employment period, or stipulate only the amount to be
contributed by the employer to a member’s account for each year of active
Lance Wallach, National Society of Accountants Speaker of the Year and
member of the American Institute of CPAs faculty of teaching
professionals, is a frequent speaker on retirement plans, financial and
estate planning, and abusive tax shelters. He speaks at more than ten
conventions annually and writes for over fifty publications. 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 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. Mr. Wallach
may be reached at 516/938.5007, email@example.com, or at www.
taxaudit419.com or www.lancewallach.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.
Lance Wallach Expert Witness
Lance Wallach's Side Has Never
Lost A Case
Has never Lost a
Abusive Tax Shelter, Listed
Witness,419 Plan, Captive