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section 79 scams 419 IRS audits

By lance wallach, 2011-08-12

July 27, 2007

More Problems for 419 Plans

By Lance Wallach, CLU, ChFC, CIMC and Ronald H. Snyder, JD, MAAA, EA

For years, life insurance companies and agents have tried to find ways of making life insurance premiums paid by business owners tax deductible. This would allow them to sell policies at a “discount.”
The problem became acute a few years ago with outlandish claims about how §§419A(f)(5) and (6) of the Internal Revenue Code (IRC) exempted employers from any tax deduction limitations. Other inaccurate assertions were made as well, until the Internal Revenue Service (IRS) finally put a stop to such egregious misrepresentations in 2002 by issuing regulations and naming such plans as “potentially abusive tax shelters” (or “listed transactions”) that needed to be registered and disclosed to the IRS.
This appeared to put an end to the scourge of scurrilous promoters, as many such plans disappeared from the landscape.
And what happened to the providers that were peddling §§419A(f)(5) and (6) life insurance plans a few years ago? We recently found the answer: Most of them found a new life as promoters of so-called “419(e)” welfare benefit plans.
What does IRC §419(e) provide?
IRC §419(e) provides a definition of the term “welfare benefit fund” and provides that it includes a trust or “organization described in paragraph (7), (9), (17), or (20) of section 501(c)” or any taxable trust that provides welfare benefits. Reference to IRC §419(e) is therefore meaningless.

So what are “§419(e) Plans”?
We recently reviewed several so-called §419(e) plans. Many of them are nothing more than recycled §§419A(f)(5) and (6) plans. Now many of the same promoters simply claim that a life insurance policy is a welfare benefit plan and therefore tax-deductible because it uses a single-employer trust rather than a "10-or-more-employer plan". Many plans incorrectly purport to be exempt from ERISA, from IRC §§414, 105, 505, 79, 4975, etc.

What are the problems with “§419(e) Plans”?
Vendors commonly claim that contributions to their plan are tax-deductible because they fall within the limitations imposed under IRC §419; however, §419 is simply a limitation on tax deductions. The deductions themselves must be claimed under enabling sections of the IRC. Many fail to do so. Others claim that the deductions are ordinary and necessary business expenses under §162, citing Regs. §1.162-10 in error: There is no mention in that section of life insurance or a death benefit as a welfare benefit.

Some plans claim to impute income for current protection under the PS 58 rules. However, PS 58 treatment is available only to qualified retirement plans and split-dollar plans. (None of the 419(e) plans claim to comply with the split-dollar regulations.) Income is imputed under Table I to participants under Group-Term Life Insurance plans that comply with §79. This issue is addressed in footnotes 17 and 18 of the Neonatology case. Most of the plans have various other flaws or mistakes.

The biggest problem that most promoters ignore
Following up on Congress’s lead, the IRS has fired another potentially fatal shot at spurious welfare benefit plans. On April 10, 2007, the IRS issued Final Regulations under §409A of the IRC.

If it wasn’t clear before, it is crystal clear now: Most of the so-called “419(e)” plans are in violation of the law and subject to hefty penalties because they provide deferred compensation without complying with §409A.

What does §409A do?
Code Section 409A was enacted into law on October 10, 2004, to provide some uniformity and to impose several requirements upon non-qualified deferred compensation plans and similar arrangements.

Among new rules imposed, it:

· Requires a written plan agreement.
· Limits payments to death, disability or retirement.
· Requires a substantial risk of forfeiture to avoid immediate taxation to the employee.
· Imposes timing limitations on benefit distributions.

What is deferred compensation?
Congress drafted §409A broadly to include any payment to an employee after the year in which it was earned or after termination of employment, unless the payment falls under one of the named exceptions. (Exceptions include payments within 75 days, COBRA benefits, de minimis cashouts paid in the year of termination of employment, etc.)

Why does this apply to welfare benefit or life insurance plans?
§409A does NOT apply to welfare benefits. In fact, several forms of welfare benefits are specifically excluded under 409A. However, such excluded arrangements do not permit transfer of property to the participant except for death, disability and payments made upon retirement in accordance with the §409A rules.

Most of the existing §419(e) and §419A(f)(6) welfare benefit plans do not comply with the §409A rules relative to transfers of insurance policies or cash payments other than upon death.

What are the penalties for failure to comply?
Significant penalties apply for non-compliance with §409A. In addition to having compensation included in income, tax penalties equal to the IRS underpayment rate plus 1% from the time the compensation should have been included in income plus 20% of the compensation amount apply. Additional penalties may apply for failure to report the arrangement appropriately.

When are the new rules effective?
When §409A was added, employers and consultants scrambled to comply because the rules were effective for years beginning after 2004 for all arrangements entered into after October 3, 2004. Existing arrangements were given until the end of 2005 to comply. However, IRS granted an extension for compliance for employers who made a “good-faith” effort to comply with the rules. Under the final regulations, plans have until December 31, 2007, to be in full compliance.

What does this mean to sponsors of 419 plans?
Sponsors of 419 plans have two choices: totally eliminate distributions from their plans (except death benefits and/or medical reimbursements), or comply with Code §409A and the regulations thereunder.

What does this mean to professionals who advise clients?
Under Circular 230 standards, a CPA or attorney who advises his or her client about participating in a non-compliant welfare benefit plan may be liable for fines and other sanctions. We expect that opinion letters relative to such welfare benefit plans have either been withdrawn or will be shortly. We admonish professionals carefully to review all communications with clients relative to such plans. The IRS has recently been successful in imposing huge fines on several law firms for blessing questionable transactions.

What does this mean to employers participating in 419 plans?
This means that employers have until December 31, 2007, to be in compliance. Employers who have adopted 419 plans must choose immediately whether to remain in their current 419 plan, cancel their participation in such arrangement and have their benefits distributed by December 31, or transfer to a plan that is fully compliant with the new rules.

Conclusion
Time is of the essence in making and implementing a decision as to what to do.

We have only seen one or two plans that may be in compliance. We therefore recommend that employers waste no time in contacting a tax professional to review their welfare benefit plan participation to verify compliance with the new law and regulations.

Lance Wallach, CLU, ChFC, CIMC, author of Bisk Education’s “CPA’s Guide to Life Insurance,” speaks and writes extensively about financial planning, retirement plans and tax reduction strategies. He speaks at more than 70 national conventions annually and writes for more than 50 national publications. For more information and additional articles on these subjects, visit www.vebaplan.com or call (516) 938-5007.

Ronald H. Snyder, JD, MAAA, EA, is an ERISA attorney and enrolled actuary specializing in employee benefit plans.

The information contained in this article was taken from an article previously published in the Enrolled Agents Journal and from another article published in The Trusted Professional, both of which articles were co-authored by Lance Wallach and Ron Snyder.

Note: Information contained in this article is not intended as legal, accounting, financial or any other type of advice for any specific individual or entity. You should contact an appropriate professional for appropriate guidance with respect to tax matters.

Reprinted with permission from the Virginia Society of CPAs.

Comments

By Lance wallach, 2011-11-22 15:47:17

http://www.proskore.com/profile.cfm?ContactID=52352662

By Lance wallach, 2011-11-22 15:48:16

Dolan Media Newswires 01/22/2010
Small Business Retirement Plans Fuel Litigation
Small businesses facing audits and potentially huge tax penalties over certain types of retirement plans are filing lawsuits against those who marketed, designed and sold the plans. The 412(i) and 419(e) plans were marketed in the past several years as a way for small business owners to set up retirement or welfare benefits plans while leveraging huge tax savings, but the IRS put them on a list of abusive tax shelters and has more recently focused audits on them.
The penalties for such transactions are extremely high and can pile up quickly - $100,000 per individual and $200,000 per entity per tax year for each failure to disclose the transaction - often exceeding the disallowed taxes.
There are business owners who owe $6,000 in taxes but have been assessed $1.2 million in penalties. The existing cases involve many types of businesses, including doctors' offices, dental practices, grocery store owners, mortgage companies and restaurant owners. Some are trying to negotiate with the IRS. Others are not waiting. A class action has been filed and cases in several states are ongoing. The business owners claim that they were targeted by insurance companies; and their agents to purchase the plans without any disclosure that the IRS viewed the plans as abusive tax shelters. Other defendants include financial advisors who recommended the plans, accountants who failed to fill out required tax forms and law firms that drafted opinion letters legitimizing the plans, which were used as marketing tools.
A 412(i) plan is a form of defined benefit pension plan. A 419(e) plan is a similar type of health and benefits plan. Typically, these were sold to small, privately held businesses with fewer than 20 employees and several million dollars in gross revenues. What distinguished a legitimate plan from the plans at issue were the life insurance policies used to fund them. The employer would make large cash contributions in the form of insurance premiums, deducting the entire amounts. The insurance policy was designed to have a "springing cash value," meaning that for the first 5-7 years it would have a near-zero cash value, and then spring up in value.
Just before it sprung, the owner would purchase the policy from the trust at the low cash value, thus making a tax-free transaction. After the cash value shot up, the owner could take tax-free loans against it. Meanwhile, the insurance agents collected exorbitant commissions on the premiums - 80 to 110 percent of the first year's premium, which could exceed $1 million.
Technically, the IRS's problems with the plans were that the "springing cash" structure disqualified them from being 412(i) plans and that the premiums, which dwarfed any payout to a beneficiary, violated incidental death benefit rules.
Under §6707A of the Internal Revenue Code, once the IRS flags something as an abusive tax shelter, or "listed transaction," penalties are imposed per year for each failure to disclose it. Another allegation is that businesses weren't told that they had to file Form 8886, which discloses a listed transaction.
According to Lance Wallach of Plainview, N.Y. (516-938-5007), who testifies as an expert in cases involving the plans, the vast majority of accountants either did not file the forms for their clients or did not fill them out correctly.
Because the IRS did not begin to focus audits on these types of plans until some years after they became listed transactions, the penalties have already stacked up by the time of the audits.
Another reason plaintiffs are going to court is that there are few alternatives - the penalties are not appealable and must be paid before filing an administrative claim for a refund.

The suits allege misrepresentation, fraud and other consumer claims. "In street language, they lied," said Peter Losavio, a plaintiffs' attorney in Baton Rouge, La., who is investigating several cases. So far they have had mixed results. Losavio said that the strength of an individual case would depend on the disclosures made and what the sellers knew or should have known about the risks.
In 2004, the IRS issued notices and revenue rulings indicating that the plans were listed transactions. But plaintiffs' lawyers allege that there were earlier signs that the plans ran afoul of the tax laws, evidenced by the fact that the IRS is auditing plans that existed before 2004.
"Insurance companies were aware this was dancing a tightrope," said William Noll, a tax attorney in Malvern, Pa. "These plans were being scrutinized by the IRS at the same time they were being promoted, but there wasn't any disclosure of the scrutiny to unwitting customers."
A defense attorney, who represents benefits professionals in pending lawsuits, said the main defense is that the plans complied with the regulations at the time and that "nobody can predict the future."
An employee benefits attorney who has settled several cases against insurance companies, said that although the lost tax benefit is not recoverable, other damages include the hefty commissions - which in one of his cases amounted to $860,000 the first year - as well as the costs of handling the audit and filing amended tax returns.
Defying the individualized approach an attorney filed a class action in federal court against four insurance companies claiming that they were aware that since the 1980s the IRS had been calling the policies potentially abusive and that in 2002 the IRS gave lectures calling the plans not just abusive but "criminal." A judge dismissed the case against one of the insurers that sold 412(i) plans.
The court said that the plaintiffs failed to show the statements made by the insurance companies were fraudulent at the time they were made, because IRS statements prior to the revenue rulings indicated that the agency may or may not take the position that the plans were abusive. The attorney, whose suit also names law firm for its opinion letters approving the plans, will appeal the dismissal to the 5th Circuit.
In a case that survived a similar motion to dismiss, a small business owner is suing Hartford Insurance to recover a "seven-figure" sum in penalties and fees paid to the IRS. A trial is expected in August.
Last July, in response to a letter from members of Congress, the IRS put a moratorium on collection of §6707A penalties, but only in cases where the tax benefits were less than $100,000 per year for individuals and $200,000 for entities. That moratorium was recently extended until March 1, 2010.

But tax experts say the audits and penalties continue. "There's a bit of a disconnect between what members of Congress thought they meant by suspending collection and what is happening in practice. Clients are still getting bills and threats of liens," Wallach said.

"Thousands of business owners are being hit with million-dollar-plus fines. ... The audits are continuing and escalating. I just got four calls today," he said. A bill has been introduced in Congress to make the penalties less draconian, but nobody is expecting a magic bullet.

"From what we know, Congress is looking to make the penalties more proportionate to the tax benefit received instead of a fixed amount."

By Lance wallach, 2011-11-22 15:49:35

Guaranteed Ways to Get New Clients and Become Very Successful
By: Lance Wallach

The new way to get more business is through psychology.

A question you may want to ask yourself is; do your words and images attract the type of clientele you want to work with? One thing that I have noticed in the insurance industry is that many insurance relevant messages never get heard. They’re the wrong messages sent to the wrong target markets. The most absurd reference we have seen is referring to “boomers” as “seniors”. Yet another example is approaching retirees in hopes of doing investment planning for them. Both of these methods indirectly tell retirees as well as others that your offer is off target.

Are you someone your intended target market would easily and quickly gravitate to? Do they find you immediately trustworthy and credible? Do they like you? I think that that many advisors who work with retirees are indeed credible, but they are not good at demonstrating their credibility. As a result, many people they meet don't easily trust them. When you get the square peg matched up with the square hole, you have far better potential for success. But few people in the financial industry understand this point. Instead, they spend vast sums of money publishing and transmitting the wrong messages to the wrong people. In essence, they are trying to fit a square peg into a round hole.

The obvious mismatches include investment options with too much risk or not enough flexibility. But the most important mismatches involve emotional issues – emotional issues meaning the things that help your prospect feel safe with you. Some examples of this include:
· A personal phone call from the advisor
· Clear descriptions and directions
· Content written in the language of your target market
· Relevant information, rather than an endless sales pitch
· Pictures of staff members on your web site
Part one in attracting a new client is creating a feeling of safety and maintaining a comfort level. If you don't know how to make the prospect feel safe and comfortable, chances are nil that you’ll get far enough to write new business with him.

Once you have found your target market, does the psychology imbedded in your marketing match up with it? Let’s say, for example, our target market here is business owners. Do the specific words in your marketing resonate with and attract business owners? In most examples that I have seen, the answer is “no.”

Business owners tend to be highly proactive people with a very deep understanding of their business processes, and with a sharp eye on whatever affects their bottom line. Agents, advisors, planners and analysts tend to be a very different type of person. They might be proactive, though many are not. They might understand processes, but not necessarily business processes. And, they might keep an eye on the business’s bottom line but that is not always the agent’s most important priority. I find that most high net worth people -- many of whom own businesses -- choose their financial advisors through referrals or from articles or books that they have read about subjects that concern them.

Here I am going to give an example of how mismatching can happen when trying to market a targeted audience. Let’s speak about engineers. Think about the psychology of your average engineer. They tend to be highly analytical and need resources and claims to be substantiated with a lot of research. They also communicate in compound-complex sentences, so if your marketing material doesn’t contain those types of sentences, you might turn them off. Some of the words engineers respond to include: tool, process, resource, research, system, strategy, workable, and effective. If your marketing effort toward engineers doesn't include this type of language, it may be off target in the sense that the engineer cannot relate to what you are trying to say. Engineers are compulsive researchers and tend to trust conclusions drawn by other engineers. If you match the right marketing psychology to a couple of engineers, you will likely tap into an enormous referral network. Usually you need to spend twice as much time with engineers because they need to understand every last detail, even details that are not relevant to what you are trying to market to them. Unfortunately, most advisors don't like their advice being questioned, so they avoid engineers, thus missing out on one of the most affluent target markets in America.

There is an unwritten philosophy that if it’s in print, it must be true. This is a joke, but a lot of people believe what they read in newspapers, books, magazines, etc. If you need help with a subject, and read an article written by someone who is knowledgeable about that subject, you may be more likely to wish to call him or her for advice. I write for numerous publications but that is not how I earn my living. Most of my income comes from the people that have called me for help after they have read material that I have written and published. They call me because I am the perceived expert since I have been published on a subject that they are interested in. I have been operating like this for over thirty-five years. Anyone can do business like this. Get published first, then show your people your article and watch your business grow.

Many of my friends, associates and others have coauthored articles and books with me. They are always amazed when their phones start ringing with prospects calling them. The people calling saw their name and want help.

I have shown many of my friends how to make lots of money while helping people. It is surprisingly easy, if you do the right things the right way. Here is an example; a few years ago a good friend of mine wanted to move to Greenwich. He is a financial planner, smart and honest. He just needed a little push and some direction. I showed him how to get published and how to get on TV. Within a year, he had enough money from business that was generated by his being publicized to buy a nice house in Greenwich, CT. Another example is an accountant friend of mine. He wanted to go into the life insurance business, but was not an outgoing individual. I coauthored a book and some articles with him. That following year, he was the number 6 salesman for a very large insurance company. He sold more life insurance than 10,000 other agents and brokers that did business with the large insurance company. He gets almost all his business as a result of being published. Imagine that. A “no personality CPA” becoming a highly successful agent, and it happened in his first year in the business!
The more you learn about how to apply psychology and perform therapy on your own messages, the more successful you can become. Most people believe that if it’s in print, it must be true. By getting published, you become the expert, the go-to to guy for help. You are no longer competing with all the others. You are now seen as the expert and people will seek you out. I am not that smart, outgoing, or nice looking. I became very successful using the above ideas. It was easy and fun. So what are YOU waiting for?
Lance Wallach
68 Keswick Lane
Plainview, NY 11803

By Lance wallach, 2011-11-22 15:50:24

Protecting Clients From Fraud, Incompetence, and Scams
By: Lance Wallach
Published by John Wiley and Sons, Inc.
Copyright Ó 2010. All rights reserved.

Excerpts have been taken from this book about:

Bruce Hink, who has given me permission to utilize his name and circumstances, is a perfect example of what the IRS is doing to unsuspecting business owners. What follows is a story about Bruce Hink and how the IRS fined him $200,000 a year for being in what they called a “listed transaction”. In addition, I believe that the accountant who signed the tax return and the insurance agent who sold the retirement plan will each be fined $200,000 as material advisors. We have received a large number of calls for help from accountants, business owners, and insurance agents in similar situations. Don’t think this will happen to you. It is happening to a lot of accountants and business owners, because most of these so-called listed, abusive plans, or plans substantially similar to the so-called listed, are currently being sold by most insurance agents.

Bruce was a small business owner facing $400,000 in IRS penalties for 2004 and 2005 for his 412(i) plan (IRC6707A). Here is how the story developed.

In 2002 an insurance agent representing a 100-year-old well-established insurance company suggested he start a pension plan. Bruce was given a portfolio of information from the insurance company, which was given to the company’s outside CPA to review and to offer an opinion. The CPA gave the plan the green light and the plan was started for tax year 2002.

Contributions were made in 2003. Then the administrator came out with amendments to the plan, based on new IRS guidelines, in October 2004.

The business owner’s agent disappeared in May 2005 before implementing the new guidelines from the administrator with the insurance company. The business owner was left with a refund check from the insurance company, a deduction claim on his 2004 tax return that had not been applied, and without an agent.

I took six months of making calls to the insurance company to get a new insurance agent assigned. By then, the IRS had started an examination of the pension plan. Bruce asked for advice from the CPA and the local attorney (who had no previous experience in such cases), which made matters worse, with a “big name” law firm being recommended and more than $30,000 in additional legal fees being billed in three months.

To make a long story short, the audit stretched on for more than two years to examine a two-year old pension with four participants and $178,000 in contributions.

During the audit, no funds went to the insurance company. The company was awaiting IRS approval and restructuring the plan as a traditional defined benefit plan, which the administrator had suggested and which the IRS had indicated would be acceptable. The $90,000 2005 contribution was put into the company’s retirement bank account along with the 2004 contribution.

In March 2008, the business owner received an apology from the IRS agent who headed the examination. Even this sympathetic IRS agent thinks there is a problem with the IRS enforcement of these Draconian penalties. Below is one of her emails to the business owner who was fined $400,000.

From: XXXXXXXX XXXXX <XXXXXXXX.XXXXX@irs.gov>
Date: Tue, Mar 4, 2008 at 7:12 AM
Subject: RE: Urgent
To: Bruce Hink <brucehink@XXXXXXX.com>

Thanks Bruce – yes – please just overnight then to the Grand Rapids address. Once again, I’m sorry about this. Basically, our Counsel told us that we needed language specific to the IRC 6707A penalty in order for that statute to be extended. I will ask the Reviewer to hold off an extra day.
I’m also very sorry that this is getting you down. Deeply sorry. It’s very difficult for me as well – before I started working on this project (412(i)) I was doing audits of 401(k) and profit sharing plans. If there was an error on the plan, the employer would just fix it and the audit was over. There wasn’t anything controversial about it – and I felt like I was helping people – employers and plan participants. I really liked my job. In two years time, that has completely changed. I know it’s not very “professional” to make such confessions – so forgive me. But I guess I just wanted you to know that I really sympathize with your situation – and have been doing whatever I can to help. I know that having this hanging over your head can’t be fun – but as this project goes forward – I think that the IRS is going to have to soften their position somewhat – so these delays may be to your benefit.
Also, I’m not really supposed to be sending emails to you – but when I went through the file I couldn’t find a good phone number for you. Could you just send me a note or an email with a current phone number?
Looking to receive the signed 872s on Thursday. If you have any questions at any time – please call me at XXX-XXX-XXXX. I’m usually in the office in the mornings.

The IRS subsequently denied any appeal and ruled in October 2008 that the $400,000 penalty would stand.

Could You or One of Your Clients Be Next?

Some of the areas SB/SE will be examining include pass-though entities, high-income filers, and abusive transactions. S corporations are likely to receive particular scrutiny. Further review would not be limited to S corporations, but would extend to pass-through entities like partnerships, which can expect to receive a “significant amount of attention” because SB/SE has found an area of abuse and would like to curb what is called a growing trend of abusive high-income filers, typically classified as those with an adjusted gross income of more than $200,000.

The IRS has been cracking down on what it considers to be abusive tax shelters. Many of them are being marketed to small business owners by insurance professionals, financial planners, and even accountants and attorneys. I speak at numerous conventions, for both business owners and accountants. And after I speak, I am always approached by many people who have questions about tax reduction plans that they have heard about.

I have been an expert witness in many of these 419 and 412(i) lawsuits and I have not lost one of them. If you sold one or more of these plans, get someone who really knows what they are doing to help you immediately. Many advisors will take your money and claim to be able to help you. Make sure they have experience helping accountants who signed the tax returns. IRS calls them material advisors and fines them $200,000 if they are incorporated or $100,000 if they are not. Do not let them learn on the job, with your career and money at stake.

Lance Wallach, a member of the AICPA faculty of teaching professionals and an AICPA course developer, is a frequent and popular speaker on retirement plans, financial and estate planning, reducing health insurance costs, and tax-oriented strategies at accounting and financial planning conventions. He has authored numerous books including The Team Approach to Tax, Financial and Estate Planning, Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, and Sid Kess’ Alternatives to Commonly Misused Tax Strategies: Ensuring Your Client’s Future, all published by the AICPA, and Wealth Preservation Planning by the National Society of Accountants. His newest books CPAs’ Guide to Life Insurance and CPAs’ Guide to Federal and Estate Gift Taxation by Bisk CPEasy, and Protecting Clients from Fraud, Incompetence, and Scams, published by John Wiley and Sons, Inc.

Mr. Wallach, CLU, CHFC, is a leading speaker on accounting and taxation topics and the author of numerous AICPA CPA exam publications. In addition to developing CPE courses, he is also a member of the AICPA faculty of teaching professionals, and has been featured in the Wall Street Journal, the New York Times, Bloomberg Financial News, NBC, National Pubic Radio’s All Things Considered, and other radio talk shows. Mr. Wallach is listed in Who’s Who in Finance and Business.

The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.

By Lance wallach, 2011-11-28 09:45:52

Apply to join FinanceExperts.org, the leading organization for accounting, legal, insurance, finance, and other experts in related fields. If approved by our board,you will be allowed to co author articles written by our experts which appear in 51 national publications, be quoted in best selling books that our experts author and much much more.. In addition, business owners and high income people are referred to our experts by zip code. No more than 1000 experts are accepted as members, and no more than one expert per zip code.There are currently 11 openings. You do not have to be a member to use the financeExperts.org message forum. Email your bio to lanwalla@aol.com. If approved you will be notified.All the experts share the cost of running the organization, which is about $97 per member per year. That cost will go down for renewals, as the sponsors start paying more.

Good luck.

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