Homer L. Richardson - Page 25

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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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