Jerry Lee Harvey - Page 17




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          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.                                       







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