From: Lance Wallach
Sent: Friday, December 23, 2011 8:46 AM
To: Jon Havicon 
Subject: Re: IRC 79

Dear Jon:

 Many of the promoters of sect.79 plans are  the same people that promoted 419 and abusive 412i plans. Most of the abuses, as of the prior plans, are in the face to face selling.
Saying that the IRS approves the plans, putting large amounts of permanent life insurance in the plans and saying that it is deductible, etc. It is the same with the sales of captive insurance. They are telling the owners of the business that they can deduct large amounts of life insurance and in later years get the money out tax free. These promoters are a lot smarter about what they put in print, than in prior years. You may want to go on Google and type in Section 79 plans and see all the promoters and others.

In the 90s I warned about abusive 419 and 412i plans but the IRS did not do much to catch the abusers for years. In 2002 I spoke at ASPA in Washington, and then had a private meeting with senior IRS and Treasury officials which was arranged by the then acting IRS Comm. and arranged by MS. Gold, giving more details.
Then the IRS really started going after all of the abusive 419 and 412i plans.This is the same pattern today. 

Lance Wallach


From: Jon Havicon
Sent: Friday, December 23, 2011 9:46 AM
To: Lance Wallach
Subject: Re: IRC 79


Thanks for the update. I'll forward to our Lead Development Center for further review.

Jon S. Havicon

IRS Agent

Sent: Thursday,

June 04, 2009 11:43 AM
To: Itzkowitz Ronald R
Subject: Lance Wallach AAACPA meeting

When I met you at the meeting, I was the first speaker, I gave you some articles. I also then emailed them to you. I am following up to see if you can use any of them, or if you have suggestions for me. Look forward to teasing you the next time that I speak, and you are there. You are a good sport.

Lance Wallach

From: Ronald Itzkowitz
To:Lance Wallach
Sent: 6/4/2009 2:03 P.M. 
Subj: RE: Lance Wallach AAACPA meeting

Hi Lance,

  I did use the copies you gave me at the meeting, however, never received any emails.  Would you be kind enough to re-send them to me.

Thank you,

Ronald R. Itzkowitz

National EP Customer Partnership Analyst

Internal Revenue Service - Employee Plans


The IRS agent pointed to in the video followed up with Lance after the AACPA convention 

Lance Wallach and the IRS 

Section 79 Help

Sent: Monday, November 28, 2011 
To: Itzkowitz Ronald R
Subject: Lance Wallach


Hope all is well with
you. I never heard from your contact about the abusive shelter information that you sent to him. This stuff on section 79 and captive is not all over the net and is sold by the same promoters that used to sell the 412i and 419 scams??????

‚ÄčLance Wallach


Sent: Monday, November 28, 2011 3:36 PM
To: Havicon Jon S
Cc: ''
Subject: RE: Lance Wallach


Hi, Jon,
  Would you please follow-up with your contact.



From:Jon Havicon
To: Lance Wallach
Sent: 12/22/2011 2:36 P.M. 
Subj: IRC 79



I heard back from my referral contact.  She said if you know of any specific examples of abuse in this area, let me know and we'll forward the our Lead Development Center.  Thanks. 


Jon S. Havicon

Internal Revenue Agent