What are participants in 412(i) plans saying!

Participants in these plans generally report the same story.



No one told me I was purchasing a tax shelter. I was making good money at the time and looking to supplement my 401(k). I was told this was the perfect plan. I was told that I could fund the plan over a 5 year period of time, and then have flexability to take money out of the plan as I needed it.



I was told (or provided) with a tax opinion letter which said the plan was in compliance with IRS regulations.



I was provided with an IRS letter of Determination which I was told indicated that the IRS had blessed the plan. What they were not told was that the letter of determination only applied to the plan documents, not the operation of the plan.



I was told in 2004 that the IRS had issued guidance but that my plan was not an abusive plan and that I should continue to fund the plan.



I was told that since my plan was not an abusive plan, I was not required to file a form 8886 on my tax return, and that if I did, I was asking for an audit by the IRS.



I have been audited by the IRS.



I have been assessed or will be assessed section 6707 penalties.

Is there any recourse against the people who sold me the plan?