A Plea for Help

412(i) Plans and Penalties

"I am a Third Party Administrator and am asking for your help. One of my clients with 4 employees who simply funded a retirement plan with $500,000 recently endured a 5.5 year IRS audit of his 412 (i) pension plan. Upon completion of the audit the client owes $55,000 in income taxes for 2004-2006 and has refunds from 2007-2008 of $55,000 (timing difference only) He owes about $30,000 in blackmail money (He really should owe nothing!). The SBSE income tax agent has threatened to assess $800,000 in penalties under Code Section 6707a. The IRS is far exceeding their authority in assessing the 6707a penalty this is totally prosecutorial abuse. WE must put a stop to this! My client cooperated and acted in good faith and did file the form 8886 (Maybe not 100% correctly but none the less, he did file the necessary forms).……"

--Dennis Cunning

  • The Millennium Plan
  • The Beta Plan- Hartford- PAC Life
  • Niche- Life Insurance Companies
  • Compass Welfare Benefit Plan
  • Sea Nine VEBA- Bisys
  • Professional Benefits Trust (PBT)
  • Advantage - Sterling- Cresp
  • Heritage Plan- Indianapolis Life Penmont -and litigation involving other similar 412i
  • Retirement Plans
  • 419 Welfare Benefit Plans

Lance Wallach Expert Witness

What is a '412(i) Plan'?

​"A defined-benefit pension plan designed for small business owners in the United States. This is a tax-qualified benefit plan, so any amount that the owner contributes to the plan becomes available immediately as a tax deduction to the company. The plan must be funded solely by guaranteed annuities, or a combination of annuities and life insurance."

Investopedia (c)2014   




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Our CPAs, Attorneys, ex-IRS agents and specialists know exactly what the IRS is looking for and how to help you avoid the huge fines and penalties they are imposing. Don't let the IRS get more of your money than they deserve simply because you failed to file a form properly.