- 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 Next
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