Tax Strategy from Inside the IRS

[00:00:00] Kevin Schneider: On this episode of the Hidden Money podcast, we're going to peel back the curtain a little bit, in more ways than one. The first way is we actually have an employee of ours, Gabe Hogan, on the podcast. Gabe has a interesting background, which I'll let him get into, but he's actually gone from the bad side to the good side.

He is an ex-IRS agent. So, we're going to get some really in-depth, behind-the-scenes of how this whole machine works, and how do we protect ourselves from it. So, Gabe, welcome to the podcast! We're glad you're here.

Mike Pine: I just want to add real quick, Kevin, not only is he an ex-IRS agent, he's also an attorney. The first time our firm has ever decided to hire an attorney, took some serious soul-searching, but we found one that still has a soul. So yeah, welcome Gabe!

Gabe Hogan: Oh, thank you. Yeah, I think I've just been going down the checklist of infamous career paths. Even at one point in my life, I was a car salesman. So, I think ‘dentist’ may be next. No, thanks for having me on guys. It's been a wild ride.

And so, public accounting was always my goal, when I was back in school, and decided to go take the scenic route to get into public accounting. So, went to law school, and then got a Master's of Tax Law afterwards, then immediately came into the accounting world, helping people with not only just compliance work preparation, but also audits, what we call controversy... so, fighting the IRS. Then life happened, and I got recruited over to the Death Star, as I say, and became a federal agent with the IRS for four years, until finally realizing the machine was broken enough to where I needed to get out.

It wasn't the spot that God had for myself, for my family. So, decided to leave and transition out to help people on the outside. I really enjoy being able to help people. And so, having that experience and education, and everything else, it's been great, and then you guys gave me an opportunity to come over and help people here at Revo.

Mike Pine: The IRS' loss is our gain, which is very typical in this world that we practice. And so, we're super glad to have you. We have a tax attorney now on the team who knows the ins and outs of the IRS, and like Kevin said, let's peel back some layers and let's get into the mystery of- What is this IRS?

How does it work? How does it not work? --is probably a better question, but how is it supposed to work?

Gabe Hogan: The IRS is considered the largest accounting firm in the world. So, like any accounting firm, there's going to be divisions- Operations, Enforcement, Compliance, IT, just the whole gamut of things.

The problem comes in, though, is that you are using taxpayer money, and then the bureaucracy, red tape, and then politicians. [00:03:00] So, instead of having a free market enterprise where people can pivot, ditch things that aren't doing well, or make things more fluid, things are really just caught up in the red tape, and then the politics of it all, and egos, and everything else that can happen to really... just think ‘things in quicksand’, sadly enough.

So, to start off, you know, everybody sees the IRS as this big, bad thing that's scary, and that's by design. They want that to happen. Because the IRS is the only government agency that is net positive with income. It's the only one that actually receives money and is revenue-generating. It's there to try to get people to comply with the tax laws. The tax laws are created by politicians, and the internal revenue code, and then, the IRS is set to help with enforcement and compliance.

Well, the IRS has two kinds of theories on this: one is that you can have compliance by enforcement. Think of, like, a police officer giving speeding tickets. The more speeding tickets he gives, the speed’s going to go down. Well, the IRS knows that it's never going to be able to have compliance at an enforcement level, or full compliance, so what they do is they have the theory of voluntary compliance.

So, they basically make sure to have the infrastructure and support to allow people to do this as they want, and then, have the enforcement side to create a little bit of fear and penalties and everything else to where people will do what they want even if they don't feel like they should. So, that's the high level view of the IRS and, kind of, what they're slated to be doing.

Kevin Schneider: Yeah, that's a good analogy there because a lot of CPAs also find themselves being the police officers. And that's where our industry really hurts is when we are viewed as administrators or enforcers on behalf of the IRS. And that's why we started this podcast. That's why our firm is built around the culture we've created is, we don't believe in that.

We don't believe that CPAs are police officers enforcing the internal revenue code. We are serving our clients. We are for their benefit, and the tax code has a huge amount of incentives and ways to utilize and grow wealth, and to grow your portfolio while saving taxes.

I mean, there's so many, and there is going to be some wrist-slapping, and some actual ticket giving in there, but it has to function that way, but we're not here to make you comply at your detriment. We're going to keep you in compliance. We're never going to go outside the laws. So, like, as a CPA, just think of us like [00:06:00] we're going to be driving this bus. We're not going to put you in danger and speed, but we know the quickest route to get to the end goal, which is well.

So, we know some shortcuts. We know ways to get around certain traffic areas that everyone's piled into. We can get around those. So, that is our job here is to make sure that we're in compliance. We're not skirting compliance. We're not going to get ticketed.

Gabe Hogan: Oh, absolutely.

Kevin Schneider: But we're also not going to be on the side of the road with a radar gun on our own clients.

Gabe Hogan: No, exactly. The traffic analogies just work really well for me when talking about tax law, and when I'm talking to clients and just the general population.. It's like being on a highway. The highway side may say 60 miles an hour, but if everybody's doing 65 or 70, then you know that you're going to be able to do 65 or 70.

And that's where, even though the letter of the law is one thing, the actual application, and in real life, it may be different, and knowing that kind of risk area is important because you don't want to be doing 70 miles an hour in a school zone. That's reckless. That's something that you're going to get in trouble.

You could get major penalties, you could do damage, you could hurt yourself or others. So, we want to make sure that as advisors for our clients that we're putting everything in context. And that's one thing the IRS, believe it or not, actually teaches and instills in their employee and the enforcement side is there's this theory of ‘reasonable’. Everything needs to be reasonable, and it's material.

So, that's where we look at it, and we need to gauge where we're standing on our advice, and what we're doing for our clients on- Is this reasonable? Is it on the target? And I tell my employees and my staff this all the time that the IRS sees a return, and they just want it to be materially correct. So, here's the target.

If it's on the target, that's going to be pretty good. It doesn't have to be in the bullseye, but if it's off the target, we just need to bring that back over and get it into the realm of reasonable. The thing is, though, in the accounting world and in the tax world, a lot of people that do this as a profession are very legalese.

We're very detail oriented. We're very nit-picky. We're nerds. We like things to be very precise. And so, that's where we get in trouble, is that our innate nature is to do, see things in very black and white terms. And when you work with a lot of accounting firms and CPAs and tax preparation, that's where you're right, we can actually stop being the advocate, and start being the police even though we're not tasked with that.

Mike Pine: Yeah. You bring up a very interesting point. Tax is not black and white. Now, when I was going to college and grad school, they taught it as if it was black and white, my professor did. I hated that, but in reality, yeah, there's some things that are black and white. If you have income, and in most cases it's probably taxable income, you need to report it, but then, there's also deductions. [00:09:00]

So, how do they teach the IRS to navigate that area? Because anytime I've ever called the IRS, which I haven't done this in decades, but I used to call and say, “Hey, this is what my taxpayer wants to do. What are the rules?” --That was a dumb place to go. They would always tell me that's against the rule.

That's definitely black and white. And then, as I progressed in my career, I've learned there's very little black and white. Almost 99% of tax law is gray area. How do they teach that concept? Or do they teach that concept at the IRS?

Gabe Hogan: Oh, absolutely. It's very similar to an adversarial type of mentality that they give is, ‘Is there enough law to make this the government's favor?’ –and so, you're taught to go into every file and you default to the government's favor. You don't want to default to this person's side, because just like in other industries where you're, kind of, rewarded or told this is what you're tasked with doing as an agent, every file we're told, “You need to analyze that file when it hits your desk, figure out how much meat is on the bone, or how much the government can benefit.

If there's not enough there, let it go. Get the next one and try to make sure that your time is justified.” --So, billable hours at accounting firms and law firms and everything else, it's the same thing with the IRS. We have to justify our time. So, if I have a file and I'm spending days, weeks, months, even over a year on it, I better be showing an ROI and a return on investment on that file.

So, that's where the agents will, kind of, cherry pick and figure out where there's enough meat on the bone on certain files, dig their teeth in, and then just always side with the government because that's what they're told. And that's what your performance reviews are based on is, How much are you closing these files? How productive are you?

They can't necessarily tie those together because of the RA 95 Act basically said there can't be these thresholds, or anything else, but it is still loosely talked about in efficiency on, they're tied with the dollar amount that you're bringing in, but it's unofficial.

Kevin Schneider: It's almost like you're in a court battle. In an audit, it seems like both parties are trying to, kind of, defend their position. And since the tax code is gray, the IRS is saying, “We view it this way.” --But we're saying, “We view it this way.”

--and then, you, kind of, come at a standstill. You've got to, within a reasonable process, be able to say, “Hey, we made this position because of this, this, and this.” --Right? So, it's like they're trying to prove you guilty, even though you may not be. They're trying to slam the hammer down when you may have done nothing wrong.

It's just, you're guilty because they want you to be, it sounds like.

Gabe Hogan: Well, absolutely, but that's the way the tax law is written is because IRC 6001, basically, puts everything in the ball court of the taxpayer and the preparer, saying, “You have to [00:12:00] provide and substantiate, and provide all the support at the request of the commissioner.” --So, you have to report all your income, but everything that you're basing, and deducting, and trying to do. I'm allowed to just come in and say, “If you don't prove it, then it goes away.”

Mike Pine: –So, the presumption of innocence, that's supposed to be in the fabric of our constitution of our entire nation. We're supposed to be presumed innocent until proven guilty, but it doesn't seem like it's that way when I'm dealing with the IRS on behalf of a client. It seems the opposite.

Gabe Hogan: It is, but that's by design and that's legal. It's a civil matter.

This is like suing somebody. So, we're talking a completely different legal precedent and mentality that's taken on by the court systems, by the IRS and by everybody else.

And if you want the benefit of the tax code, you have to prove it, and so, it is absolutely the mentality of that. So, that's one of the biggest things preparers and advocates need to do for their clients and for themselves, is to make sure to have support and documentation, and not wade into waters that they may not understand.

Kevin Schneider: Yeah, that's very true. And that's just being honest to prepare, being honest with themselves, saying, “Hey, I don't know if I could take this position.” --And honestly, we get a lot of clients, new clients, who have that, where they'd listen to our podcast. They might take an episode to their CPA, and the CPA is like, “Nope, it's all passive.”

--Or, “You know, you can't do this.” --And they come to us, we're like, “No, you can.” --But props to that other CPA. They're doing something they're not comfortable with, and if they got audited, and they perform something they hear on a podcast, that would be very reckless of them to just blindly do that.

So, they're doing their due diligence saying, “Hey, here's what I'm comfortable with. You need to go find someone else who understands this better or is more comfortable taking this position.” --And that's perfectly fine and healthy.

Gabe Hogan: Oh, 100%.

Mike Pine: Sorry, Gabe. I got such a strong opinion here, I feel like I need to share a little bit more. It is not constitutional the way the IRS works, in my humble opinion. We should be given the benefit of the doubt. We should be innocent until proven guilty. Whether it's civil, criminal, I don't care. It's not fair.

But that's why I think, we at this firm, and you share the passion that Kevin and I have, and the rest of our team shares. That is our job, then: to make it more fair, to even the playing field.

And I think our profession, sadly, has not done a great job of it in the aggregate. Our profession, like Kevin just said earlier, we've acted like we're the policemen for our clients.

That's not true. We are the advocates for our clients, taxpayer advocates. That's what we are.

Gabe Hogan: Oh, absolutely! I couldn't agree more. It's very frustrating. I think that being on both sides of the table for long enough now, and having experience, I channel that frustration into, “Okay. Let's think outside the box, and let's get around this. Let's figure out a way to navigate the broken system.” –And that's where I agree with you that it is a broken system.

I've had cases that, literally, I've developed for a year and a half that were yanked off [00:15:00] my desk because of political connections, and it just felt wrong and dirty, because as an enforcement, you want to get the bad actors out of the pool. 

You want to enforce the law against the people that need it to be enforced, but you don't want the innocent people or the people that made mistakes to get caught in that net.

And going back a little bit to, kind of, what Kevin was talking about a little bit ago, about just the interpretation and professional responsibilities, I always like to remind people that the internal revenue code right now is well over 6 million words. 

To give you an idea, the Bible is 600,000 words, and we have seen countries, and just entire populations fight over the meaning, and the definition, and the interpretation of that document.

Now, put a few more zeros on the end of that, and that's what we get to. There is no one on the inside or the outside that fully understands the internal revenue code.

The good thing is, there’s so many avenues to get where you want to go, so whenever I do help people walk through these processes, I always let them know the buck doesn't stop at where you're frustrated.

There’s things that we can do to get the outcome that we want. We just have to be creative sometimes

Kevin Schneider: Yeah. And I remember my very first audit. I'm out of college. I'm working as a tax associate at a shop over here in Dallas. Client got audited, and I was going to be the staff assigned to it, so I had a senior and a manager on it with me.

The agent came in, and so, I just sat across this guy and I did the initial interview, the intake, and I was just answering the questions truthfully. He goes, “Yeah, I don't see any problems here, here, here..”

--He was literally done by lunch! And this was like a million dollar plus income earner, and it was done by lunch. I mean, he did not care one bit.

Gabe Hogan: So, there are different levels. Think of it like in the military, you have your infantry level that are going to be your frontline guys going in. Then you get further up the ranks, and then, you're going to have your generals, and your admirals, and everything else.

And so, it's the same thing inside the IRS. You have, kind of, different divisions and levels. Right now, currently... and this could all change because of the Inflation Reduction Act and the $80 billion of infrastructure that we're trying to pour into the IRS.. So, we have, what we call, general program, and that's, typically, under the umbrella of SBSE, which is Small Business / Self-Employed. So, what that division is doing, is that's the division that's covering the audits for most people that are making at, or less than $5 million a year. So, if your AGI- Adjusted Gross Income- is $5 million or less a year, more than likely, you're going to be picked up by that net.

Then, at the next level, you're going [00:18:00] to what's called Large Business & International (LB&I). That's a pretty big step up. You're dealing with professionals, at that point, inside the IRS, and that's from $5 million to $20 million. It's AGI, it's going to be high net-income, or high net-wealth.

And then, at $20 million above, it's global high net-wealth, and that's even a higher echelon where you're dealing with, kind of, the cream of the crop, the best of the best agents, teams, and they're really diving in. So, with that said, each tier, you can imagine, it's, kind of, the A squad, B squad and C squad.

$5 million and less, you're dealing with people that have, they're probably lifers. They've probably been in the IRS for a while. Most of them aren't licensed. Most of them have a bachelor's degree, hopefully in Accounting, or enough accounting hours, and they're, kind of, just thrown in the mix, and then, they're given the high workloads.

Mike Pine: And like you said, it's hard to blame the agents because it's the broken system of government work.

And probably told, just like you, “Don't be too good, be mediocre.”

--If that's your marching orders from your boss, and that's what it takes to keep your job, or even get promoted, it's a human condition. Of course, we're going to change to do that.

Kevin Schneider: That would be very frustrating to work for, and I can feel where you would be stuck. Like, where am I in five years?

Mike Pine: So let me just throw this out here, Kevin. If you happen to be working for the IRS, and if you feel like you're stuck, and you know you can do more, and you want to achieve your potential, please give us a call. We're hiring. We will not ask you to be mediocre. We will ask you to do your best. So, give us a call.

Find us at www.hiddenmoney.com, please. We're hiring.

Kevin Schneider: Yeah.

Gabe Hogan: There's still, to this day, there's a system called IDRS, and that is the biggest kind of data infrastructure that keeps all of our tax records in the United States. It's run on MS DOS! I literally had to log in and do CD backslash to get to another drive.

There are some apps and widgets that now help to where you don't have to do this. For those, the younger listeners here, MS DOS was something that was created in the '80s, with computers when they used to be the size of the room, and floppy disks were six and a half inches, still to this day!

It is inefficient. It's slow. There's mistakes. We still fax. We still use fax, and even at this firm, we have to fax things to the IRS all the time.

 Mike Pine: All the reason we still have a fax system... is to fax the IRS!

Kevin Schneider: That's it. Who communicates by fax?? Is it just, they don't want to update their system?

Gabe Hogan: It's because you have government agents that they don't want to rock the boat. So, there's no advancement because there's no reward for advancement.

Kevin Schneider: Yeah.

Gabe Hogan: We are seeing some changes. We are seeing the IRS that's starting to finally get with it a little bit more. We're seeing a little bit more technology utilized. We're seeing AI get used to analyze some [00:21:00] of this.

So, we are seeing a trend. However, it is slow, it's not efficient, and we're going to see people caught up in... good people caught up in bad nets, because of it.

Kevin Schneider: I want to ask a question that we get asked all the time. How am I audited? How am I picked? We always hear about red flags. I don't want to draw attention. I don't want a red flag, red flag, red flag. What is a red flag? How does the IRS flag something? It seems like on our side, it's all just computerized, right? The most popular notice is the CP 2000, where it's just, “Hey, you didn't report your dividends. You didn't report your cap gains. You missed a W2.”

--I mean, that's all computer generated. Tell me about this red flag ordeal that we always have to field that question for, and how do you get picked for an audit?

Gabe Hogan: So, Season 3, this is going to be our topic for the whole Season 3, it sounds like, for the podcast. I'll give you the fastest CliffsNotes version I can, yes, red flags are a thing. You do want to have a risk-based analysis on what you're doing on what the IRS may be looking for.

Every year, they publish a document called the Dirty Dozen. This is something that you want to make sure that your tax professionals are aware of. Here at Revo, we are very up to date on everything that's happening. We have our finger on the pulse, and the zeitgeist of what to know, and where those are. 

Doing anything that's risky, so, in the past, we've seen home-office was one of them: different card expenses.. But to get to the higher level, more like conservation easements, R&D credits, and employee retention credits. Those are really going to be the big ones because those have the biggest meat on the bone for the IRS come in, prove that you were wrong, and get a huge chunk of change back.

The highest risk right now is being a high-income taxpayer. Being over the $400,000 mark on your AGI, that raises your risk. Being over a million, raises it more. Being over $5 million, raises it even more. Every return in America that gets filed goes through this algorithm. The algorithm is actually top-secret clearance because it's a matter of national security for our income.

So, every return that comes through gets graded, and it's given a DIF (Discriminant Index Function) score, and that DIF score's basically, say, the high DIF score raises the chances of, if an audit's to happen, the government may be able to get more money out of this.

And then, you get the call, and that's when your dance card gets called for the audit. That's the standard route.

There's also special projects, and that's where we get into If you claim to conservation easements, yours may be cherry-picked out because they're looking for anybody that claims certain deductions, or anything else, and they're going to do a 'research you' kind of [00:24:00] project, and then pull that out.

So, those are the standard way of just when you get audited out of the blue. Two other things that can happen with an audit is- you go file an amended return for a refund, and the IRS is saying, “Okay, well, hold on. Before we give you that $100,000 refund, we're going to go ahead and audit you now, and see if this is right, and then, if you were right on all the other things.”

--So, by filing an amended return for a refund, that's a pretty common way to get audited. And then, also, a fun one is called whistleblowing. I always say it's the disgruntled spouse way of getting audited. Typically, you have a spouse that is, like, “Hey, I'm going through divorce.

My ex runs a business and claims zero income. That's not true. Here's some bank statements.” --The neat thing about the whistleblowing is you actually get a percentage of whatever the government collects. So, there's incentive there to whistleblow on people.

Mike Pine: But you don't get in any trouble if you whistleblow a false whistle?

Gabe Hogan: No, no, because every whistleblower case goes through the review process. So, just because you whistleblow somebody doesn't mean they're going to get audited. We review those files, and then, the whistleblowers are always protected. The person getting audited is never allowed to know who, why, how this came down.

Mike Pine: Again, unconstitutional. You have the right to face people testifying against you, except with the IRS. So, you mentioned the process of getting flagged or getting pulled for an audit usually involves a human being, at some point, looking at your return.

So, one thing I learned early in our careers- I was still at Price Waterhouse Coopers, a partner told us this. We filed cost-segregation reports and catching up with some depreciation. We did 481(a) adjustments for these big old apartment complexes. Well, the first time we did it, we did not attach the cost-seg report to the actual tax return, and boom! They got pulled for an audit, and the partner said, “Look, this is what happens.

They saw this big negative adjustment to income.” --So, human being looked at it, and it looked fishy because there wasn't enough documentation. So, he told me, “From here on out, we're always going to attach the cost-seg report with the tax return.”

Since I've done that, now it's been 20 years, and we electronically filed tons of tax returns with cost segregation reports, catching up with the depreciation, I have not once had one of our clients get audited when we've attached the cost-seg report.

So, what I think happens when those returns get pulled for a human being to look at it, they look at it, but then they see this professionally done cost segregation report, and it matches with the numbers that we put on the tax return. And that's why it never pulls an audit, because someone looks at it, and they say, “Oh, well, they're not cheating. They actually did this, and went through this process. It's not worth me trying to audit them because I'm not going to win.” --Is that reasonable thinking?

Gabe Hogan: Oh, it's more than reasonable. You're 100% accurate in your way of thinking. Every time I got a file, and I was going to start and I was doing my research, it's the ‘smell test’. The first thing I ever [00:27:00] do is open the file, research the taxpayer. I'm getting on all of their websites, social media, their history, pulling everything before I even give that, and if somebody's giving me a file with some substantiation, and, or if they're documented in a way, or using words or languages that makes me see, like, okay, this person is actually trying, then it's passing the ‘smell test’. But whenever anybody's slapping down $20,000 as a miscellaneous expense, well, there you go.

That's going to be real easy for me to get in and out, and that's what I'm looking for as a government agent. I'm looking for low-hanging fruit because I'm lazy. I want to get in and out of this. I want to get my money for the government, get my pat on the head and close this file. And if I see a miscellaneous, or a big deduction, then I could say, “Hey, show me the substantiation.”

--They don't show it. I'm able to make the adjustment and get out. But in your case, like you said, you just took away my motivation. Why would I touch something if I know I'm going to have to fight you on it?

You're doing a really good job for your clients by doing that and being proactive, and that's where the value comes in on having a good professional.

Mike Pine: Because there's an art to it. It's not just the facts. It's not just following the rules. Like there's nowhere in the tax code that says you're supposed to attach a cost-seg report when you're doing a 481(a) adjustment. Nowhere it says it's not required, but by doing it, you are serving the clients better.

We're being advocates for taxpayers better. It's important that people understand that. TurboTax won't tell you that. H&R Block probably doesn't know that.

Gabe Hogan: But a good defense wins championships.

Mike Pine: Good point.

Kevin Schneider: That's right. And if you're not doing anything shady, we show our work. It's like, we're not going out of bounds. We're not driving our bus a hundred miles an hour in the school zone. We're in the speed limit. It just so happens we know the shortcuts, and we're going to show our work, and we'll show you the map that we use to get there, and we're not scared of that.

If we had a million dollar taxpayer, and we're able to eliminate half their taxable income with a cost-seg, and we show our work, that's less risky than someone making $200,000 and slapping a bunch of even numbers on a Schedule C, of $10,000 travel, $20,000 miscellaneous, $5,000 meals, and then submitting that, even though they're way lower bracket, way less income.

Gabe Hogan: Well, and that's one of the things, where round numbers was always the first thing- that's your first week of training as an IRS agent- is look for round numbers. If you see round numbers, you know immediately to throw that as an issue to question and try to get them to prove, or make the adjustment.

Kevin Schneider: Yeah. Very interesting.

Gabe Hogan: And then, one other thing, is a lot of people are getting really frustrated right now, and I'm getting this from clients, is just the operational side. A lot of delays.

This is because of, sadly, just [00:30:00] employees, and then, also, the changing of systems and everything else. So, when you have a refund that's delayed, correspondence that's delayed, that's just part of the process. There's not much you can do as a tax professional on the outside to grease those wheels.

I hate to just tell people, but I've seen things delay up over a year. But because of the process, and the way... we're talking about the government and the funding... no congressman, or anybody else, will ever touch this and say, “IRS isn't allowed to.” --or, “We need to speed up these refunds.”

--Because of the amount of fraud, identity theft, and everything else, it is very important for tax professionals to advise their clients to try to not pay-in more, because that money could get tied up. Let them know that- make sure that you don't need this money right away, because we'll get it back, but there is no telling when, sometimes.

Mike Pine: Yeah, it's infuriating.

Kevin Schneider: Well, Gabe, this was one of the most interesting podcasts we have, just kind of getting a peek behind the inner workings of this IRS body. It's kind of mysterious with all the clearance, and algorithms, and just news articles that come out.

We don't know what's real, but having you come out from the inside, and give us a little insight has just been awesome. I want to have you on. I think we're going to have a lot of questions on this topic. It is a very hot-button issue.

Gabe Hogan: I just want to say thank you, both, for not only the opportunity to come on the podcast, but to work with a great team and help represent some amazing clients. It's an honor and a privilege, and yeah!

Mike Pine: Absolutely. It goes both ways, Gabe. We are honored to have you on the team, and ultimately, we're all working together to help our clients take back what is rightfully theirs, at www.hiddenmoney.com