Some Accountants Will Be In Trouble Because of IRS Notice 2007-83

Lance Wallach

Most accountants are not aware of the problems that their clients and themselves may face if any of their clients are or were in a 419 welfare benefit insurance plan. These popular plans were sold by many insurance agents and financial planners, and even some accountants and attorneys. In October 2007, the IRS issued two notices and a revenue ruling which, among other things, designated most of these plans as listed transactions. If the accountant is deemed to be a material advisor, she has to file with the IRS to avoid a $100,000 fine. Some of these plans have already gone out of business and a few of these plans have stolen the participants' money. For published articles on this and similar subjects see

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,, or at or

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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