WILL THE MAI, AI, APPRAISAL BE SUED OUT OF BUSINESS? YES

WILL THE MAI, AI, APPRAISAL INSTITUTE BE SUED OUT OF BUSINESS? YES!

The ai, mai, appraisal institute is assuredly heading for the dung heap of corrupt organizations.  For years they have succeeded, without prosecution, in committing bank fraud, tax fraud, and a pay to play professional enrichment scheme.  Today they are faced not only with prosecutions from the IRS but civil lawsuits from investors who fell for their overprices fraudulent appraisals.

 

GOOD RIDDANCE TO BAD RUBISH

 

Settlement of Syndicated Conservation Easement Transaction 

 

in Cases Docketed Before the U.S. Tax Court Additional Information Cancel Date: Until Further Notice I. PURPOSE This notice provides guidance about the settlement option offered by the Office of Chief Counsel (CC) in Notice 2017-10 syndicated conservation easement (SCE) transactions in certain cases pending before the United States Tax Court. 

1. What are the financial terms of the settlement? The partnership (or the group in the case of a settlement with fewer than all of the partners) will make a lump sum payment representing the aggregate tax, penalties, and interest due from each partner (Settlement Amount). This lump sum payment must be remitted to CC when the partnership (or the group in the case of a settlement with fewer than all of the partners) returns the signed Closing Agreement.

The settlement resolution offers partners who engaged in an SCE transaction the opportunity to resolve their docketed case in an efficient manner. Based on the existing state of the law, partners should not expect a better result at trial or in the Independent Office of Appeals (Appeals) than what is provided in this settlement. Partners who choose not to participate in this initiative run the risk of full disallowance of all deductions claimed with respect to the SCE transactions and imposition of penalties, including:

- An accuracy-related penalty under section 6662 (calculated in most cases at a 40 percent rate). - Alternatively, an accuracy-related penalty under section 6662A (calculated at either the 20 percent rate or 30 percent rate in the case of a nondisclosed transaction). - The 75 percent civil fraud penalty under section 6663, in appropriate cases.

Comments

[COMMERCIAL APPRAISER]

1.

CCNotice.
. Details available on settlements in syndicated conservation easement transaction initiative

The Internal Revenue Service this week released Notice 2021-001, containing information on Chief Counsel's settlement initiative for certain pending Tax Court cases involving abusive syndicated conservation easement transactions. Prior coverage of the settlement initiative can be found in IRS news release IR-2020-196.

The IRS encourages investors to seek independent professional assistance with the settlement terms to help them assess their hazards of litigation. Investors are advised to obtain counsel from competent, independent advisers not related to or recommended by the transaction promoter.