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petitioner caused approximately 65 crates to be shipped to Trupin
in Vancouver, Canada.
From October 1986 through June 1994, petitioner and/or
Trupin lent a concert grand piano and two stools worth $1 million
to the Museum of Fine Arts in Boston. On June 22, 1994,
petitioner requested that the piano be removed from the Museum of
Fine Arts and shipped to Trupin in Washington State.
On December 15, 1986, petitioner purchased property in
Claverack, New York (Claverack property), without a mortgage. On
June 12, 1992, title to the Claverack property was transferred to
Blue Lotus. Various items of furniture, collectibles, and other
valuable property were stored in crates and containers in or on
the Claverack property. On June 15, 1995, the IRS seized the
Claverack property and its contents as part of its collection
efforts with respect to the amounts owed by petitioner and Trupin
for 1982 through 1986. On June 27, 1995, the IRS changed all of
the locks on the Claverack property and placed on the property
notification that the seizure had occurred. Thereafter,
petitioner illegally entered the Claverack property and removed
paintings and other items. She was indicted as a result. In
February 1997, petitioner entered into a plea agreement in the
U.S. District Court for the Northern District of New York, in
which she pleaded guilty to a violation of section 7212(b), to
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