Atlanta Attorney Admits Guilt in IRS Tax Shelter Fraud Scheme

Atlanta Attorney Pleads Guilty to Obstructive Practices Against the IRS

In an Atlanta courtroom last week, a local attorney found himself entangled in a legal web of his own making, leading to a guilty plea. Vi Bui, a name now well-known in this legal brouhaha, has admitted to obstructing the IRS as part of his role in promoting abusive syndicated conservation easement tax shelters. This case shines a spotlight on a complex scheme that sought to exploit tax loopholes for the benefits of wealthy clients.

The Intricate Web of Syndicated Conservation Easement Tax Shelters

Let’s break this down. Bui was a partner at Sinnott & Co., an Atlanta-based company, joining forces with Jack Fisher, Thomas Sinnott, and others in what the courts have described as a plot to mislead the IRS. This operation spanned from at least 2012 to May 2020 and revolved around the creation of partnerships to purchase land. In a not-so-surprising plot twist, these lands were donated as conservation easements. This, however, wasn’t a simple act of charity. Instead, it laid the foundation for fraudulent tax deductions. The land’s value was inflated through dubious appraisals, leading to shockingly high charitable contribution deductions for investors in the partnership.

Backdating Documents and Deceptive Practices

What’s a good scheme without a bit of falsification? Bui and his colleagues went the extra mile to dodge the IRS. They didn’t just stop at creating partnerships and inflating values. Allegedly, they also engaged in backdating and falsifying documents to make it seem as though participants bought into the tax shelters on time. This meant fiddling with subscription agreements, checks, and other types of paperwork—which Bui, on occasion, did himself.

Bui was acutely aware that the IRS might soon take note of these goings-on, so he and others orchestrated efforts to disguise the partnerships as legitimate real estate entities. They went so far as to fabricate lengthy documents, conduct sham votes on the land’s fate, and fill every paperwork nook and cranny with falsifications.

Facing the Music

Unfortunately for Bui and those involved, some undercover investigative efforts in 2018 did lead to the uncovering of these deceptive tactics. On one occasion, Bui even crafted false documents to convince the IRS that certain transactions occurred before they actually did, with past dates conveniently pre-dating tax returns.

For his extensive involvement in, and benefits from, this scandal, Bui is now looking at a potentially three-year prison sentence and other penalties, set to be determined on February 13, 2025. He’s not alone in facing justice, either. Fisher and Sinnott were sentenced to 25 and 23 years, respectively, with numerous other participants already having entered guilty pleas.

A Collaborative Take-Down

The legal proceedings and investigations are the result of collaborative diligence between the Justice Department’s Tax Division and the IRS Criminal Investigations (IRS-CI). As more details of this scheme unravel, the story serves as a potent reminder that the structures intended to serve communal good, such as conservation easements, become ineffective when exploited for personal gain.

This case of tangled deception highlights the efforts needed not just in circumventing tax systems but also the uncompromising pursuit to hold accountable those who attempt to undermine public trust. The repercussions extend beyond Bui, reverberating through legal channels and reinforcing the commitment to maintaining transparent practices in financial and real estate domains.