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Kibort also relied on Young's testimony at the bond hearing in
St. Louis and the proffer. In addition, Kibort relied on a brief
filed in the Court of Appeals for the Eleventh Circuit which
dealt with the dismissal of petitioner's criminal tax indictment.
All the information Kibort used to make the jeopardy assessment
was public record.
The jeopardy assessment, like the termination assessment,
was litigated. It proceeded through an administrative level of
appeals and was then petitioned to the District Court for the
Southern District of Florida. The District Court held that the
jeopardy assessment was reasonable. See Harvey v. United States,
730 F. Supp. 1097 (S.D. Fla. 1990).
Kibort was also involved in issuing the notice of deficiency
for the years 1978 through 1983. The principal difference of
this calculation from the calculation for the jeopardy assessment
was that certain expenditures were added to unreported income
that were either unexplained or cash. None of the information
Kibort used came from Young, Snyder, or Parenteau unless it was
public record.
BCCI Returns Petitioner's Funds to the United States
BCCI deposited $4,602,776.17 of petitioner's money into the
registry of the District Court for the Southern District of
Florida in April 1990. To find out whether this represented all
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