The 60 millionaires who paid no tax and the richest and poorest postcodes revealed
As readers of this blog and other blogs and news in general know, the Government has been pursuing a major tax crimes case against Robert Brockman. See One Big Fish Indicted and Lesser Big Fish Achieves NPA for Cooperation (Federal Tax Crimes Blog 10/16/20), here; and Brockman Found Competent to Stand Trial (Federal Tax Crimes Blog 5/24/22), here.
Brockman died late yesterday, Friday, June 5. See David Voreacos and Neil Weinberg, Robert Brockman, Software Developer Who Fought IRS, Dies at 81 (Bloomberg 8/6/22), here (highly recommended). This moots the criminal case, but the civil side (involving both administrative investigations and civil cases) will continue.
One of the IRS civil initiatives that continues is a jeopardy assessment (meaning an assessment made for a tax normally requiring a notice of deficiency and opportunity to litigate in the Tax Court before assessment). I discuss jeopardy assessments in my Federal Tax Procedure Book (2022 Practitioner Edition) beginning at p. 503. (The book may be downloaded at the links provided here.) A jeopardy assessment permits a taxpayer assessed to bring an expedited proceeding in the district court, and Brockman has done so. Brockman v. United States (S.D. Tex. Case No. 4:22-cv-00202), Courtlistener docket entries here. According to the docket entries, oral argument was held on 8/3/22 (Dkt. #56 & 57) and the Court notified of the death on 8/6/22 (Dkt. #59). (I could not find on PACER a similar notice to the Court, but the same Judge is assigned to both cases; the CourtListener docket entries for the criminal case are her
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