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Beginning long before the years in issue, petitioners were
involved in continuing disputes with the Internal Revenue Service
(IRS). Petitioners were associated with an organization known as
the American Law Association, which conducted seminars promoting
the creation of foreign trusts for the purpose of decreasing or
avoiding taxes. In 1978, petitioners established three foreign
business trusts in the Turks and Caicos Islands. Mr. Nordbrock
was convicted of violating section 7206(1) for filing false
income tax returns for 1981 and 1982. Mr. and Ms. Nordbrock were
convicted of violating section 7206(1) for filing a false amended
income tax return for 1981. These convictions were affirmed on
appeal by the Court of Appeals for the Ninth Circuit in United
States v. Nordbrock, 952 F.2d 408 (9th Cir. 1992) (unpublished
opinion). In 1992, the District Court for the District of
Arizona imposed a lifetime injunction prohibiting Mr. Nordbrock
from preparing tax returns for others. The lifetime injunction
was affirmed on appeal by the Court of Appeals for the Ninth
Circuit in United States v. Nordbrock, 38 F.3d 440 (9th Cir.
1994).
In October 1992, respondent seized property located on Swan
Road in Tucson, Arizona. The IRS sent a notice of seizure to
Swan Business Organization as nominee of Mr. Nordbrock on
October 9, 1992.
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