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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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