Tax :: IRS Audits 419, 412i, Captive Insurance Plans With Life Insurance, and Section 79 Scams | ArticleBiz.com

Tax :: IRS Audits 419, 412i, Captive Insurance Plans With Life Insurance, and Section 79 Scams | ArticleBiz.com

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    IRS Audits 419, 412i, Captive Insurance Plans With Life Insurance, and Section 79 Scams
    Home Finance Tax
    By: Lance Wallach Email Article
    Word Count: 1693 Digg it | Del.icio.us it | Google it | StumbleUpon it




    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, Mc

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