William J. McCorkle - Page 14

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          (2) the jury rendered a special verdict of forfeiture, and (3)              
          the District Court entered the forfeiture order.  Moreover,                 
          petitioner argues that, since respondent was a bona fide                    
          purchaser for value reasonably without cause to believe the $2              
          million remittance was subject to forfeiture, he could have                 
          defended against the forfeiture order and, because he failed to             
          do so, should be barred from trying to collect the 1996 tax                 
          liability.                                                                  
               Respondent counters that, on account of his criminal                   
          conviction, petitioner cannot challenge the validity of the                 
          forfeiture order or respondent’s compliance with it.  Respondent            
          also argues that, since, at the time he received notice of the              
          forfeiture order, he had not assessed petitioner’s 1996 income              
          tax liability, he had no standing to make a claim as a bona fide            
          purchaser for value.                                                        
          III.  Analysis                                                              
               A.  Introduction                                                       
               The jury in the criminal case returned a special verdict of            
          forfeiture with respect to the $2 million remittance.  In                   
          returning the special verdict, the jury necessarily found that              
          petitioner had transferred $2 million of laundered proceeds to              
          the IRS.  Cf. United States v. McCorkle, 321 F.3d at 1294 n.2.              
          Thereafter, the District Court entered the forfeiture order, the            
          United States presumably notified respondent of the order, and,             






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