- 17 - aircraft at issue had been purchased in Oklahoma along with two other aircraft. The purchase records indicated that there was a wire transfer of $750,000 from BCCI in Panama, in addition to $300,000 in currency. At the time of the termination assessment, however, Kibort did not know about the $750,000 wire transfer from Panama. Kibort knew only that three aircraft had been purchased, and he allocated a purchase price to the aircraft at issue for purposes of the termination assessment. Based on the sale price and basis, there was a profit on the aircraft at issue. On December 31, 1986, the IRS made three termination assessments: One against Intercontinental Jet, Inc. (Intercontinental Jet), another against petitioner personally, and a third against petitioner as a transferee of Intercontinental Jet. Petitioner challenged the termination assessments, and Kibort continued to work on the case. Petitioner went through the administrative level of appeals of the termination assessments and then petitioned the District Court for the Southern District of Florida regarding the assessments. An open hearing regarding the termination assessments was held in West Palm Beach, Florida, before the same judge that had heard petitioner's criminal tax prosecution.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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