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IRS Proposed Assessment of Listed Transaction Penalties Upon Small Businesses
Fox Rothschild LLP 
[Guidance Overview] June 15, 2010
Excerpt: Many taxpayers adopted 419(e) plans based upon representations of insurance professionals that the plans were legitimate welfare benefit plans and had no idea they were engaging in a listed transaction. Vociferous complaints from these taxpayers caused Congress to impose a moratorium on assessment of section 6707A penalties. The moratorium expired on June 1, 2010[.]
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