Audits of section 79, captive insurance, 412i and 419 scams

Audits of section 79, captive insurance, 412i and 419 scams: .  If an IRS audit disallows the § 419 plan or the § 412(i) plan, not only does the taxpayer lose the deduction and pay interest and penalties, but then the IRS comes back under IRC 6707A and imposes large fines for not properly filing. Insurance agents, financial planners and even accountants sold many of these plans. The main motivations for...