Can be written off effective Dec 31st, 2009 as a fraud/embellzement. Its a Ponzi. The Wells Notice is your proof. The fraud was uncovered by the FBI/SEC and, yes the IRS, in 2009. And thats the major issue, "When was it Discovered".
IRS website has several 2009 Revenue Rulings (maybe Revenue Procedures) on this issue. Due to "Madolf" Ponzi.
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