- 12 -
of this case was set forth in a Notice of Determination
Concerning Relief From Joint and Several Liability Under Section
6015 dated June 29, 2000. The stated reason for the
determination denying relief was as follows: “You had actual
knowledge or should have known of the tax deficiency items. You
participated in a fraudulent scheme to transfer assets between
spouses. It would not be inequitable to hold you liable
considering all facts and circumstances.” Material attached to
the determination explained petitioner’s employment by RRI and
Prudential, which led to the conclusion that she had knowledge of
the tax liabilities; her execution of a separation agreement
signed April 15, 1993, acknowledging claims of tax deficiencies
then pending; the liquidation of assets by petitioner and Trupin
through Sotheby’s and through Blue Lotus, as petitioner’s
nominee; false testimony of petitioner’s then husband, D’Aunay;
transfers of assets to Canada and otherwise as a means of placing
the proceeds of sale beyond the reach of collection by the IRS;
conviction of petitioner of “forcible rescue of seized property”;
and other conclusions regarding petitioner’s lack of credibility.
During the course of discovery in this case, petitioner
refused to answer questions concerning assets that were
transferred to her and/or that petitioner owned since 1980 and
her annual net worth for each year since 1980. She refused to
disclose any residence other than her mother’s address in Tulsa,
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011