419 Plan Tax Controversies (Audits, Appeals and Tax Court)

It's not all planning.  Sometimes the IRS might disagree with planning you did with other advisors and you need to find counsel to ensure that your rights are protected, the facts are interpreted accurately and the law applied correctly.  David Neufeld is among the few lawyers in this country who fully understand the mechanics and legal issues surrounding what has become known as “419 Plans,” welfare benefit plans often used by small companies and funded with life insurance.  For that reason taxpayers throughout the country seek his services in dealing with the Internal Revenue Service in audits, appeals and in the Tax Court. 

We can help you deal with:

• audits, appeals and Tax Court
• issues involving 419 Plan deductions and the taxation of withdrawals
• listed transaction issues including filing Form 8886 and fighting the section 6707A and section 6662A penalties

See also: Captive Insurance Companies, 419 Plan Expert Witness and Life Insurance Trustee Risk Management.

Some of the Section 419 Welfare Benefit Plans:

• NOVA Benefit Plans (run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others), including: the SADI Plan, the Grist Mill Plan, Life One, among others
• Benistar Plans (also run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others)
• Greater Metropolitan
• Sterling Benefit Plan (run by Ronald Snyder)
• Millenium Plans
• CJA & Associates (run by Raymond Ankner)
• Sea Nine VEBA
• Compass Welfare Benefit Plan
• Sunderlage Resource Group/SRG International (run by Tracy Sunderlage, among others)
• Restricted Property Trust (RPT) (run by Ken Crabb)