- 25 - 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.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011