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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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