Page:T.C. Memo. 2012-281.pdf/16

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The District Court subsequently issued forfeiture orders as to petitioner and Mr. Hovind. Under the forfeiture orders, petitioner and Mr. Hovind were liable individually and jointly in the amount of $430,400. On June 27, 2007, the court entered its first Order Forfeiting Substitute Property against petitioner and Mr. Hovind, which forfeited petitioner’s and Mr. Hovind’s interests in account 8577 and 10 properties.[1] On October 8, 2008, the court entered its second Order Forfeiting Substitute Property, which forfeited petitioner’s and Mr. Hovind’s interests in account 1872.[2]

VIII. Civil Examination

In 2007 respondent began an examination in respect of petitioner and Mr. Hovind. IRS Revenue Agent AlyceFaye was assigned to petitioner’s case. Revenue Agent AlyceFaye mailed petitioner a letter requesting that petitioner

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    release and required him to pay a $2,000 fine, a $5,800 special monetary assessment, and $604,875 in restitution.

  1. The properties included the 5720 and 5800 North Palafox properties, the 21-23, 29, 100, 116, and 400 Cummings Road properties, and the 12 and 120 Oleander Road properties.
  2. On December 30, 2008, the U.S. Court of Appeals for the Eleventh Circuit affirmed petitioner’s and Mr. Hovind’s convictions and the forfeiture orders. United States v. Hovind, 305 Fed. Appx. 615 (11th Cir. 2008). Pursuant to Fed. R. Evid. 201, we take judicial notice of the Court of Appeals’ opinion.