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419 , 412i , 419e , captive insurance , section 79 , international taxes , irs audits , FBAR , Offshore Tax Shelters ,
Welfare Benefit Plan , Cash value life insurance , Tax Penalties , IRS penalties , Defined benefit pension , Listed
transactions , tax avoidance , welfare benefit fund , 419af6 , abusive tax shelter , AICPA , malpractice , expert witness ,
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International revenue services , material advisor , Tax resolution services , 6707a , s corp , c corp , amnesty , Offer and
compromise , OIC , CPA , IRS
Welfare Benefit Plan , Cash value life insurance , Tax Penalties , IRS penalties , Defined benefit pension , Listed
transactions , tax avoidance , welfare benefit fund , 419af6 , abusive tax shelter , AICPA , malpractice , expert witness ,
8886 forms , reportable transactions , tax audits , Bankruptcy , abusive tax shelters , Certified public accountant ,
International revenue services , material advisor , Tax resolution services , 6707a , s corp , c corp , amnesty , Offer and
compromise , OIC , CPA , IRS
NCCPAP November 2010 Newsletter 2010
Business Owners in 419, 412i, Section 79 and Captive Insurance Plans Will Probably Be
Fined by the IRS Under Section 6707A
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 the taxpayer does not necessarily have to
make a contribution or claim a tax deduction to be deemed to participate. Section 6707A of the Code imposes severe penalties
($200,000 for a business and $100,000 for an individual) for failure to file Form 8886 with respect to a listed transaction. But a
taxpayer can also be in trouble if they file incorrectly. I have received numerous phone calls from business owners who filed and
still got fined. Not only does
the taxpayer have to file Form 8886, but it has to be prepared correctly. I only know of two people in the United States who
have filed these forms properly for clients. They told me that the form was prepared after hundreds of hours of research and
over fifty phones calls to various IRS personnel. The filing instructions for Form 8886 presume a timely filing. 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 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
they 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 the deductions
taken in prior years. 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. It follows that taxpayers who no longer enjoy the benefit of those large deductions are no longer
“participating” in the listed transaction.
But that is not the end of the story. 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. This language may provide the taxpayer with a solid argument in the event of
an audit.
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, financial and estate planning, and abusive tax shelters. He writes about
412(i), 419, and captive insurance plans; speaks at more than ten conventions annually; writes for over fifty publications; is
quoted regularly in the press; and has been featured on TV and radio financial talk shows. Lance has written numerous books
including Protecting Clients from Fraud, Incompetence and Scams (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. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxadvisorexperts.org or www.taxaudit419.com, www.
lancewallack.com
Lance Wallach
68 Keswick Lane
Plainview, NY 11803
Ph.: (516)938-5007
Fax: (516)938-6330 www.vebaplan.com,
National Society of Accountants Speaker of The Year
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.
Business Owners in 419, 412i, Section 79 and Captive Insurance Plans Will Probably Be
Fined by the IRS Under Section 6707A
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 the taxpayer does not necessarily have to
make a contribution or claim a tax deduction to be deemed to participate. Section 6707A of the Code imposes severe penalties
($200,000 for a business and $100,000 for an individual) for failure to file Form 8886 with respect to a listed transaction. But a
taxpayer can also be in trouble if they file incorrectly. I have received numerous phone calls from business owners who filed and
still got fined. Not only does
the taxpayer have to file Form 8886, but it has to be prepared correctly. I only know of two people in the United States who
have filed these forms properly for clients. They told me that the form was prepared after hundreds of hours of research and
over fifty phones calls to various IRS personnel. The filing instructions for Form 8886 presume a timely filing. 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 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
they 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 the deductions
taken in prior years. 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. It follows that taxpayers who no longer enjoy the benefit of those large deductions are no longer
“participating” in the listed transaction.
But that is not the end of the story. 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. This language may provide the taxpayer with a solid argument in the event of
an audit.
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, financial and estate planning, and abusive tax shelters. He writes about
412(i), 419, and captive insurance plans; speaks at more than ten conventions annually; writes for over fifty publications; is
quoted regularly in the press; and has been featured on TV and radio financial talk shows. Lance has written numerous books
including Protecting Clients from Fraud, Incompetence and Scams (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. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxadvisorexperts.org or www.taxaudit419.com, www.
lancewallack.com
Lance Wallach
68 Keswick Lane
Plainview, NY 11803
Ph.: (516)938-5007
Fax: (516)938-6330 www.vebaplan.com,
National Society of Accountants Speaker of The Year
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.
Accounting Today
Don’t Become a ‘Material Advisor’
July 1, 2011
By Lance Wallach
Accountants, insurance professionals and others need to be careful that they don’t become what the IRS calls material advisors.
If they sell or give advice, or sign tax returns for abusive, listed or similar plans; they risk a minimum $100,000 fine. They will
then probably be sued by their client, when the IRS finishes with their client
In 2010, the IRS raided the offices of Benistar in Simsbury, Conn., and seized the retirement benefit plan administration firm’s
files and records. In McGehee Family Clinic, the Tax Court ruled that a clinic and shareholder’s investment in an employee
benefit plan marketed under the name “Benistar” was a listed transaction because it was substantially similar to the transaction
described in Notice 95-34 (1995-1 C.B. 309). This is at least the second case in which the court has ruled against the Benistar
welfare benefit plan, by denominating it a listed transaction.
The McGehee Family Clinic 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 assessed tax deficiencies and the enhanced 30 percent penalty under Section 6662A, 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.
In rendering its decision, the court cited Curcio v. Commissioner, in which the court also ruled in favor of the IRS. As noted in
Curcio, the insurance policies, which were 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. The excessive cost of providing death benefits was a reason for the court’s finding
in Curcio that tax deductions had been properly disallowed.
As in Curcio, the McGehee court held that the contributions to Benistar were not deductible under Section 162(a) because the
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 policy lapse.
Companies should carefully evaluate their proposed investments in plans such as the Benistar Plan. The claimed deductions will
be disallowed, and penalties will be assessed for lack of disclosure if the investment is similar to the investments described in
Notice 95-34, that is, if the transaction is a listed transaction and Form 8886 is either not filed at all or is not properly filed. The
penalties, though perhaps not as severe, are also imposed for reportable transactions, which are defined as transactions having
the potential for tax avoidance or evasion.
Insurance agents have been selling such abusive plans since the 1990's. They started as 419A(F)(6) plans and abusive 412i plans.
The IRS went after them. They then evolved to single-employer 419(e) plans, which the IRS also went after. The latest scams
may be the so-called captive insurance plan and the so called Section 79 plan.
While captive insurance plans are legitimate for large corporations, they are usually not legitimate for small business owners as a
way to obtain a tax deduction. I have not yet seen a legitimate Section 79 plan. Recently, I have sent some of the plan promoters’
materials over to my IRS contacts, who were very interested in receiving them. Some of my associates are already trying to help
defend some unsuspecting business owners who are being audited by the IRS with respect to these plans.
Similar, though perhaps not as abusive, plans fail after the IRS goes after them. Niche was one example. The company first
marketed a 419A(F)(6) plan that the IRS audited. They then marketed a 419(e) plan that the IRS audited. Niche, insurance
companies, agents, and many accountants were then sued after their clients lost their deductions, paid fines, interest, and
penalties, and then paid huge fines for failure to file properly under 6707A. Niche then went out of business.
Millennium sold 419A(F)(6) plans and then 419(e) plans through insurance companies. They stupidly filed for a private letter
ruling to the effect that they were not a listed transaction. They got exactly the opposite: a private letter ruling saying that they
were a listed transaction. Then many participants were audited. The IRS disallowed the deductions, imposed penalties and
interest, and then assessed large fines for not filing properly under Section 6707A. The result was lawsuits against agents,
insurance companies and accountants. Millennium sought bankruptcy protection after a lot of lawsuits.
I have been an expert witness in a lot of the lawsuits in these 419, 412i, etc., plans, and my side has never lost a case. I have
received thousands of phone calls over the years from business owners, accountants, angry plan promoters, insurance agents, etc.
In the 1990's, when I started writing for the AICPA and other publications warning about these abusive plans, most people
laughed at me, especially the plan promoters.
In 2002, when I spoke at the annual national convention of the American Society of Pension Actuaries in Washington, people
took notice. The IRS chief actuary Jim Holland also held a meeting, similar to mine on abusive 412i plans. Many IRS agents
attended my meeting. I was also invited to IRS headquarters, at the request of the acting IRS commissioner, to meet with high-
level IRS officials and Treasury officials to discuss 419 issues in depth, which I did after the meeting.
The IRS then set up task forces and started going after 419 and 412i plans. I have been warning accountants to properly file
under 6707A to avoid the large fines, but most do not. Even if they file, if they make a mistake on the forms the IRS fines. Very
few accountants have had experience filing the forms, and the IRS instructions are difficult to follow. I only know of two people
who have been successful in properly filing the forms, especially after the fact. If the forms are filled out wrong they should be
amended and corrected Most accountants call me a few years later when they and their clients get the large fines, either after
improperly filling out the forms or not doing them at all, but then it is too late. If they don’t call me then, then they call me when
their clients sue them.
Lance Wallach is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters, and writes about
412(i), 419 and captive insurance plans. He can be reached at (516) 938-5007, lawallach@aol.com, or visit www.vebaplan.com.
For more information, please visit www.taxadvisorexperts.org 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@gmail.com or visit www.
taxadvisorexperts.com.
Lance Wallach
68 Keswick Lane
Plainview, NY 11803
Ph.: (516)938-5007
Fax: (516)938-6330 www.vebaplan.com
National Society of Accountants Speaker of The Year
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.
Don’t Become a ‘Material Advisor’
July 1, 2011
By Lance Wallach
Accountants, insurance professionals and others need to be careful that they don’t become what the IRS calls material advisors.
If they sell or give advice, or sign tax returns for abusive, listed or similar plans; they risk a minimum $100,000 fine. They will
then probably be sued by their client, when the IRS finishes with their client
In 2010, the IRS raided the offices of Benistar in Simsbury, Conn., and seized the retirement benefit plan administration firm’s
files and records. In McGehee Family Clinic, the Tax Court ruled that a clinic and shareholder’s investment in an employee
benefit plan marketed under the name “Benistar” was a listed transaction because it was substantially similar to the transaction
described in Notice 95-34 (1995-1 C.B. 309). This is at least the second case in which the court has ruled against the Benistar
welfare benefit plan, by denominating it a listed transaction.
The McGehee Family Clinic 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 assessed tax deficiencies and the enhanced 30 percent penalty under Section 6662A, 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.
In rendering its decision, the court cited Curcio v. Commissioner, in which the court also ruled in favor of the IRS. As noted in
Curcio, the insurance policies, which were 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. The excessive cost of providing death benefits was a reason for the court’s finding
in Curcio that tax deductions had been properly disallowed.
As in Curcio, the McGehee court held that the contributions to Benistar were not deductible under Section 162(a) because the
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 policy lapse.
Companies should carefully evaluate their proposed investments in plans such as the Benistar Plan. The claimed deductions will
be disallowed, and penalties will be assessed for lack of disclosure if the investment is similar to the investments described in
Notice 95-34, that is, if the transaction is a listed transaction and Form 8886 is either not filed at all or is not properly filed. The
penalties, though perhaps not as severe, are also imposed for reportable transactions, which are defined as transactions having
the potential for tax avoidance or evasion.
Insurance agents have been selling such abusive plans since the 1990's. They started as 419A(F)(6) plans and abusive 412i plans.
The IRS went after them. They then evolved to single-employer 419(e) plans, which the IRS also went after. The latest scams
may be the so-called captive insurance plan and the so called Section 79 plan.
While captive insurance plans are legitimate for large corporations, they are usually not legitimate for small business owners as a
way to obtain a tax deduction. I have not yet seen a legitimate Section 79 plan. Recently, I have sent some of the plan promoters’
materials over to my IRS contacts, who were very interested in receiving them. Some of my associates are already trying to help
defend some unsuspecting business owners who are being audited by the IRS with respect to these plans.
Similar, though perhaps not as abusive, plans fail after the IRS goes after them. Niche was one example. The company first
marketed a 419A(F)(6) plan that the IRS audited. They then marketed a 419(e) plan that the IRS audited. Niche, insurance
companies, agents, and many accountants were then sued after their clients lost their deductions, paid fines, interest, and
penalties, and then paid huge fines for failure to file properly under 6707A. Niche then went out of business.
Millennium sold 419A(F)(6) plans and then 419(e) plans through insurance companies. They stupidly filed for a private letter
ruling to the effect that they were not a listed transaction. They got exactly the opposite: a private letter ruling saying that they
were a listed transaction. Then many participants were audited. The IRS disallowed the deductions, imposed penalties and
interest, and then assessed large fines for not filing properly under Section 6707A. The result was lawsuits against agents,
insurance companies and accountants. Millennium sought bankruptcy protection after a lot of lawsuits.
I have been an expert witness in a lot of the lawsuits in these 419, 412i, etc., plans, and my side has never lost a case. I have
received thousands of phone calls over the years from business owners, accountants, angry plan promoters, insurance agents, etc.
In the 1990's, when I started writing for the AICPA and other publications warning about these abusive plans, most people
laughed at me, especially the plan promoters.
In 2002, when I spoke at the annual national convention of the American Society of Pension Actuaries in Washington, people
took notice. The IRS chief actuary Jim Holland also held a meeting, similar to mine on abusive 412i plans. Many IRS agents
attended my meeting. I was also invited to IRS headquarters, at the request of the acting IRS commissioner, to meet with high-
level IRS officials and Treasury officials to discuss 419 issues in depth, which I did after the meeting.
The IRS then set up task forces and started going after 419 and 412i plans. I have been warning accountants to properly file
under 6707A to avoid the large fines, but most do not. Even if they file, if they make a mistake on the forms the IRS fines. Very
few accountants have had experience filing the forms, and the IRS instructions are difficult to follow. I only know of two people
who have been successful in properly filing the forms, especially after the fact. If the forms are filled out wrong they should be
amended and corrected Most accountants call me a few years later when they and their clients get the large fines, either after
improperly filling out the forms or not doing them at all, but then it is too late. If they don’t call me then, then they call me when
their clients sue them.
Lance Wallach is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters, and writes about
412(i), 419 and captive insurance plans. He can be reached at (516) 938-5007, lawallach@aol.com, or visit www.vebaplan.com.
For more information, please visit www.taxadvisorexperts.org 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@gmail.com or visit www.
taxadvisorexperts.com.
Lance Wallach
68 Keswick Lane
Plainview, NY 11803
Ph.: (516)938-5007
Fax: (516)938-6330 www.vebaplan.com
National Society of Accountants Speaker of The Year
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.