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Case: Jeopardy Assessment Against Billionaire Tax Evader Reasonable (S.D. Tex.) (IRC §7429)

Oct. 3, 2022, 5:00 AM

Motion to abate an IRS jeopardy assessment and jeopardy levy denied as government showed the reasonableness of the assessment, a district court held. The government alleges that Taxpayer, as part of one of the largest schemes, failed to pay taxes on billions of dollars in income. Taxpayer was criminally charged but that case was dismissed when Taxpayer passed away. The government contends that Taxpayer evaded taxes by concealing his income, and that he concealed his income by using nominees to conceal his ownership and control of assets—a strategy of “owning nothing but controlling everything.” The government imposed a jeopardy assessment ...