Jerry Lee Harvey - Page 21




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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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