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March 19, 1998, that the source of the $149,200 was loans from
individuals, negotiation of a certificate of deposit, and recent
sales of merchandise in his business. Petitioner also told
Pierce that the guns seized in the raid had been stolen.
At the end of the search on March 19, 1998, petitioner was
arrested by Ozark County authorities. On March 20, 1998,
petitioner told detectives in the Christian County Sheriff’s
Department that he had lied when he said the source of the cash
seized was loans. Pierce obtained a warrant on March 25, 1998,
authorizing him to seize the $149,200 found at petitioners’
residence.
F. The Jeopardy Assessment
On November 3, 1999, respondent filed a jeopardy assessment
of $62,023 against petitioner and issued a notice of the
assessment. Petitioner filed suit in the U.S. District Court for
the Western District of Missouri to seek judicial review of the
jeopardy assessment. On June 1, 2000, Judge Ortrie D. Smith held
an evidentiary hearing, at which the parties produced witnesses
and documentary evidence. On August 16, 2000, Judge Smith issued
an order sustaining the determination that petitioner had taxable
income of $48,473 from the fencing operation in 1997. The
District Court found that petitioner had saved $100,727 from the
following sources: $5,000 saved by 1971, $2,000 saved in 1971,
$54,000 saved by 1981 from his job at International Paper Co.,
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