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prior to the liquidation of the assets is given to the
Commission [SEC] staff, and the Commission [SEC] is
given an opportunity to object [to] such liquidation,
and that the proceeds from the liquidation of any such
assets remain subject to the freeze. Clawson shall be
allowed to borrow against his Florida homestead. The
freeze shall also be modified to allow the Hatteras
boat owned by Clawson to be placed in a charter fleet,
for the purpose of generating income for Clawson to pay
his disgorgement, or to otherwise preserve assets. The
freeze shall be completely lifted as to Clawson at the
time that his disgorgement obligation is retired,
provided he is in compliance with all other orders of
the Court.
Review by Revenue Officer Riley
On or about July 30, 2001, Revenue Officer Vicki Riley
(Riley) was assigned to collect petitioners’ unpaid income tax
liability for 1999. On August 7, 2001, Riley contacted
petitioners by mail and by telephone to schedule an appointment
for the purpose of obtaining financial information from them.
Riley requested that petitioners complete a Form 433-A,
Collection Information Statement for Wage Earners and Self-
Employed Individuals (individual CIS).
On August 24, 2001, petitioners signed an individual CIS and
submitted it to Riley. On their individual CIS, petitioners
disclosed assets and equity, in pertinent part, as follows:
Asset Current Value Encumbrance Net Value
First Union Bank checking acct. $3,000 None $3,000
First Union Bank checking acct. 2,000 None 2,000
Fidelity Investments acct. 27,000 None 27,000
Investment (Sanibel-Captiva 200,000 $180,000 20,000
Airport Shuttle, Inc.)
Anticipated increase in income 500,000 None 500,000
1999 Chevrolet Suburban 30,000 25,000 5,000
1996 BMW 328 25,000 None 25,000
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Last modified: May 25, 2011