The IRS previously identified certain syndicated conservation easements as “listed transactions” under Notice 2017-10-specifically, transactions for which investors in pass-through entities receive promotional material offering the possibility of a charitable contribution deduction worth at least two and half times their investment. Today’s release indicates that for many of these transactions, the deduction taken is significantly higher than 250% of the investment. Syndicated Conservation easements were included on the IRS’s 2019 “dirty dozen” list of tax scams to avoid. Contact Lance Wallach before it's too late. 516-236-8440 wallachinc@gmail.com
Conservation easements and Captive insurance, here comes the IRS With the increased reporting requirements, IRS audits of conservation easement transactions have greatly increased. Instead of working collaboratively with taxpayers to seek a reasonable resolution, Revenue Agents are being directed to disallow deductions no matter what. With a high percentage of cases headed to litigation, taxpayers need to take every step to protect themselves now. Contact the office of Lance Wallach 516-236-8440 wallachinc@gmail.com
On Monday, December 21, 2020, Stein and Corey Agee of Atlanta, Georgia entered guilty pleas in federal court to conspiracy charges related to their roles in syndicated conservation easement transactions. These are the first guilty pleas related to the continuing IRS and Department of Justice criminal investigations across the country pertaining to easement transactions. In December 2017, the IRS issued Notice 2017-10, designating certain syndicated conservation easements as “listed transactions,” which are subject to significant scrutiny. The IRS has since announced syndicated conservation easement transactions as an area of focus for enforcement, by launching a Large Business & International Division (“LB&I”) compliance campaign in September 2018 and by including these transactions on the IRS’s annual “Dirty Dozen” list of tax scams in 2019 and 2020. In November 2019, with IR-2019-182, the IRS announced a “significant increase in enforcement actions,” explaining that coordinated examinations were being conducted by three IRS divisions: LB&I, Small Business & Self-Employed (“SBSE”), and Tax Exempt and Government Entities (“TGE”). The IRS also noted that it was working closely with the Department of Justice to pursue wrongdoers. The IRS explained they would be casting a broad net, pursuing those who promoted, assisted (e.g., appraisers and return prepayers), or participated in the transactions. Increased enforcement has resulted in many IRS victories in conservation easement cases. On October 1, 2020, IRS news release IR-2020-228 emphasized the IRS’s continued efforts to combat abusive syndicated conservation easement transactions. Lance Wallach has received hundreds of phone calls to fight the IRS and sue the promoters of these easement scams. call 516-236-8440. As an expert witness Lance Wallach has never lost a case. Google him and your advisor, Who do YOU trust. Wallachinc@gmail.com
About 84 percent of syndicated easements were in some stage of an IRS audit, according to the finance committee report, Another IRS audit target is captive insurance. The IRS has long taken note of the rise of micro-captive insurance schemes, placing the scheme on the “Dirty Dozen” of tax schemes to avoid every year since 2014. Their investigations have heated up in recent years. Lance Wallach gets hundred of calls, call 516-236-8440 to help fight the IRS and to sue the salesmen that sold people these scams. As an expert witness his side has never lost a case. Google Lance Wallach and whoever sold you the scam, Who do you TRUST. Wallachinc@gmail.com
About 84 percent of syndicated easements were in some stage of an IRS audit, according to the finance committee report, Another IRS audit target is captive insurance. The IRS has long taken note of the rise of micro-captive insurance schemes, placing the scheme on the “Dirty Dozen” of tax schemes to avoid every year since 2014. Their investigations have heated up in recent years. Lance Wallach gets hundred of calls, call 516-236-8440 to help fight the IRS and to sue the salesmen that sold people these scams. As an expert witness his side has never lost a case. Google Lance Wallach and whoever sold you the scam, Who do you TRUST. Wallachinc@gmail.com
Since micro-captive insurance companies were placed on the IRS’ “Dirty Dozen” list of tax scams in 2014 and identified as a transaction of interest in 2016, the IRS has continued to expand its enforcement efforts of what it views as abusive Micro-captive insurance arrangements. The IRS has been gathering information on taxpayers and instituted a new virtual currency compliance program in 2019. Here is an excerpt from one of their notices: “We have information that you have or had one or more accounts containing virtual currency but may not have properly reported your transactions involving virtual currency, which include cryptocurrency and non-Crypto virtual currencies.” New IRS Notice 6174-A The IRS clearly sees noncompliance on virtual currency transactions as a threat to the tax system. As if the onslaught of recent losses in Tax Court was not enough, investors in syndicated conservation easements now have more to worry about. On August 25, 2020, the Senate Finance Committee released a bipartisan report condemning syndicated conservation easements as abusive and encouraging the IRS to take further action to ferret out such abuses. Lance Wallach has received hundreds of calls, 516-236-8440 to fight IRS and sue the promotors of conservation easement, captive, and cryptocurrency plans. Google him and your advisor, who do YOU trust? wallachinc@gmail.com
The IRS released an advance version of Notice 2016-66 that identifies a type of transaction involving a “micro-captive insurance” structure as a “transaction of interest”-i.e., a tax avoidance transaction-for purposes of Reg. section 1.6011-4(b)(6) and sections 6111 and 6112. Notice 2016-66 [PDF 44 KB] states that these “micro-captive transactions” have the potential for tax avoidance or evasion. Taxpayers engaged in these transactions must disclose the transactions. A failure to disclose will be subject to the penalty under section 6707A or section 6707(a). In 2019, the IRS added syndicated conservation easement transactions to its annual "Dirty Dozen" list of tax scams. Lance Wallach has received hundreds of phone calls to fight the IRS, and to get all peoples money back from the promoters that sold these scam tax shelters. As an expert witness Lance Wallach has never lost a case. If you are in a captive or conservation easement and want to be made whole contact Wallachinc@gmail.com or call 516-236-8440. Google Lance Wallach and your advisor. Who do YOU trust.
The IRS has been cracking down on conservation easement transactions for over ten years. Nevertheless, taxpayers have continued to claim charitable contribution deductions attributable to the donation of conservation easements and promoters have continued to assemble investments utilizing conservation easement charitable deductions. The IRS began focusing on syndicated conservation easement transactions when it issued Notice 2017-10, designating syndicated conservation easement transactions as listed transactions. These syndicated investments involve the use of partnerships to raise funds from investors, who are allocated a share of a charitable contribution deduction attributable to conservation easements donated on land owned by the partnership. In fall of 2018, the IRS doubled down on its attacks of these investments when syndicated conservation easements were added to the list of LB&I compliance campaigns. While the IRS continues to crack down on these arrangements, taxpayers have continued litigating the finer points of these transactions. On the Filpside, DOJ has begun cracking down on promoters who market these transactions. Below are details on the most recent developments. Lawsuits against Promoters The government had has enlisted another tactic for shutting down conservation easements by bringing actions against the organizers of conservation easement syndication schemes. On December 28, 2018, the Department of Justice filed a compliant in the Northern District of Georgia asserting that a group of defendants assembled partnership which were “nothing more than a thinly veiled sale of grossly overvalued federal tax deductions under the guise of investing in a partnership.” The complaint asserts that the defendants’ conservation easement syndicates have generated $2 billion in conservation easement charitable contribution deductions. The complaint seeks to enjoin the defendants from continuing to promote such schemes, and asks the court to order the defendants to disgorge all profits received as a result of the conservation easement syndicates. The defendants include a conservation manager/broker dealer, an appraiser, and various professionals associated with EcoVest Capital, Inc., an entity that sponsors real estate investments focused on conservation. The promotional materials mentioned in the compliant set forth an example where in exchange for a $750,000 investment, an investor would receive $2 million of deductions, generating tax savings of $1 million. The syndicates were sold as securities exempt from registration through broker-dealers. The easement syndicates involved properties located in Alabama, Georgia, Indiana, Kentucky, North Carolina, South Caroline, Tennessee, and Texas. Any taxpayer who may have invested in a syndicated conservation easement through EcoVest or any other investment advisor should carefully review Notice 2017-10 and related the disclosure requirements for listed transactions. Those taxpayers should also consult with a tax attorney to consider strategies for mitigating any damages. Contact Details Lance Wallach Phone number : 516-236-8440 Email : wallachinc@gmail.com Address : USA
With the increased reporting requirements, IRS audits of conservation easement transactions have greatly increased. Instead of working collaboratively with taxpayers to seek a reasonable resolution, Revenue Agents are being directed to disallow deductions no matter what. With a high percentage of cases headed to litigation, taxpayers need to take every step to protect themselves now. With the increased reporting requirements, IRS audits of easement transactions have greatly increased. Instead of working collaboratively with taxpayers to seek a reasonable resolution, Revenue Agents are being directed to disallow deductions no matter what. With a high percentage of cases headed to litigation, taxpayers need to take every step to protect themselves now. Lance Wallach gets hundreds of phone calls to help people remove easement problems, fight IRS and get their money back from the promoters that sold them the easement. 516-236-8440 | Wallachinc@gmail.com
With the increased reporting requirements, IRS audits of conservation easement transactions have greatly increased. Instead of working collaboratively with taxpayers to seek a reasonable resolution, Revenue Agents are being directed to disallow deductions no matter what. With a high percentage of cases headed to litigation, taxpayers need to take every step to protect themselves now. With the increased reporting requirements, IRS audits of easement transactions have greatly increased. Instead of working collaboratively with taxpayers to seek a reasonable resolution, Revenue Agents are being directed to disallow deductions no matter what. With a high percentage of cases headed to litigation, taxpayers need to take every step to protect themselves now. Lance Wallach gets hundreds of phone calls to help people remove easement problems, fight IRS and get their money back from the promoters that sold them the easement. 516-236-8440 | Wallachinc@gmail.com
The IRS is increasing it enforcement actions for syndicated conservation easement transactions. This includes more coordinated examinations across IRS divisions, as well as more criminal investigations. The IRS believes that these audits and investigations may cover billions of dollars of potentially inflated charitable contribution deductions for qualified conservation easements made through partnerships and limited liability companies (LLCs) Google Lance Wallach and your advisor. Who do you trust? Lance Wallach 516-236-8440 Wallachinc@gmail.com
My family's summer home was just across the street from the Chestnut Street stables which was just awesome for all the kids in our family. You can't imagine what a kid's paradise it was being right across the street from all that wonderful activity. My Dad eventually bought a Crane horse for me for my 16th birthday. Her name was Bess & I loved that feisty little horse to the moon & back. We eventually moved her to Dad's farm just outside of Atlanta & I spent all my weekends with her until I had to give her up. What happy memories I have of those long ago days in Highlands.
I was lucky to meet Jonathan and his companion Thomas at a private dinner party in Hartford, CT 1986. I'll never forget how their cabbage patch doll children commanded the attention of everyone as it they were real kids. And the fascinating stories they had to share from being on the road throughout the deep south searching out and photographing the strange, the bizarre eccentric artists along the way. If you want to explore this, start with "In the Azure Over the Squalor".. a collection of quirky, memorable quotes Jonathan compiled. Then explore the bizarre eccentric characters they discover on road trips through the deep south. A start would be, "St. Eom in the Land of Pasaquan" The Life and Times of Eddie Owens Martin as told & recorded by Tom Patterson. Photographs by Jonathan Williams and others. -Jargon Society ...RIP Jonathan.
Well done, Ran! It was a treat to see the Presbyterian and Episcopal churches, the old Library, my old school, Daddy's office in between the Anderson home and their 5&10 store. BTW, I am working with The Mountain Retreat & Learning Centers in Scaly, to produce our 3rd Appalachian Spring Festival, May 22-27. We need resources for quilting, folk dancing (possibly with a band for one night's entertainment) and other appropriate traditional crafts. I will be doing a Storytelling workshop during the week; and a friend is doing the Ballad Singing; and another is doing a hiking series. I am thinking the Historic Society would help us with contacts.
OMG, I have notice this very thing in my bog garden they love to hang out in my sarracenia flowers.There is one spieces that spends a heavy silk around the mouth of my sar.judith hindle. I did happen to notice also if the spider slips up it becomes a meal also for the pitcher plant. Good luck with your studies. Kyddoemiko.
