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On June 23, 2005, the District Court entered an opinion and order
to, inter alia, “preliminarily enjoin Defendants from promoting
the sales of abusive trusts under the name of Aegis, Heritage, or
any other name, or from engaging in any other activities which
are subject to penalty under 26 U.S.C. �� 6700 and 6701”, based
principally on findings and recommendations made by a magistrate
judge in November of 2003 and February of 2004. Id.
The civil examination of petitioners’ returns resumed in
approximately April of 2003. The Government made a jeopardy
assessment with respect to petitioners’ 1996 and 1997 taxes on
May 14, 2003, after an adviser with whom they had invested
$450,000 attempted to transfer the funds to a Swiss bank account.
The notices of deficiency underlying the cases at bar were then
issued on July 10, 2003, to Mr. Richardson and on July 10 or 11,
2003, to Mrs. Richardson.10
10 Copies of the notice contained in the record bear
different dates.
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