shelter audits, 2212 views, 66likes | Lance Wallach | Pulse | LinkedIn

shelter audits, 2212 views, 66likes | Lance Wallach | Pulse | LinkedIn

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  1. syndicated conservation easement transactions
    Published on February 27, 2020
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    Speaker, author expert witness at VEBA LLC
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    The Internal Revenue Service announced today a significant increase in enforcement actions for syndicated conservation easement transactions, a priority compliance area for the agency.

    Coordinated examinations are being conducted across the IRS in the Small Business and Self-Employed Division, Large Business and International Division and Tax Exempt and Government Entities Division. Separately, investigations have been initiated by the IRS' Criminal Investigation division. These audits and investigations cover billions of dollars of potentially inflated deductions as well as hundreds of partnerships and thousands of investors.

    "We will not stop in our pursuit of everyone involved in the creation, marketing, promotion and wrongful acquisition of artificial, highly inflated deductions based on these aggressive transactions. Every available enforcement option will be considered, including civil penalties and, where appropriate, criminal investigations that could lead to a criminal prosecution," said IRS Commissioner Chuck Rettig. "Our innovation labs are continually developing new, more extensive enforcement tools that employ advanced techniques. If you engaged in any questionable syndicated conservation easement transaction, you should immediately consult an independent, competent tax advisor to consider your best available options. It is always worthwhile to take advantage of various methods of getting back into compliance by correcting your tax returns before you hear from the IRS. Our continued use of ever-changing technologies would suggest that waiting is not a viable option for most taxpayers."

    In December 2016, the IRS issued Notice 2017-10 (PDF), which designated certain syndicated conservation easements as listed transactions. Specifically, the Noctions is required under Notice 2017-10.

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  2. AMANDA J. ANDREWS ASSOCIATE COUNSEL, LEGAL DIVISION ARKANSAS INSURANCE DEPARTMENT
    "Mr. Wallach, Thank you for providing me with this information. I will review it next week and, I’m sure, be in touch. I very much appreciate your help."

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