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Former Reynolds CEO Bob Brockman asks U.S. judge to lift $1.4 billion tax levy

Former Reynolds and Reynolds Co. CEO Bob Brockman, who is billed with the greatest legal tax evasion situation by an personal in the U.S., asked a judge to lift an IRS demand from customers that he pay $1.4 billion in taxes and penalties.

The IRS has improperly imposed a so-termed jeopardy assessment, which is typically made use of when a taxpayer is “creating immediately” to go away the state and place property over and above the access of U.S. authorities, or when the taxpayer faces insolvency, Brockman’s lawyers said in a Houston federal courtroom filing Friday. None of those problems applies to Brockman, they mentioned.

“No exigency exists listed here,” lawyers claimed in the court docket filing. “There is no jeopardy. The IRS’s steps were baseless and wholly unreasonable, and need to be right away abated.”

They questioned that a judge rule on their movement in just 20 days.

The submitting expands on a lawsuit Brockman filed Thursday, and it denies key allegations that are also central to an indictment accusing him of evading taxes on $2 billion in cash flow. Brockman was indicted in October 2020 on prices of tax evasion, wire fraud, income laundering and evidence tampering in what federal prosecutors allege was an elaborate offshore plan above two decades. He has pleaded not responsible.

Brockman, 80, who was chairman and CEO of the privately held dealership management system big until eventually he stepped down in November 2020, suggests he has dementia and is not qualified for demo. Prosecutors say he’s faking. A choose who held an eight-working day listening to on the make any difference in November has however to rule.

The indictment alleges Brockman controlled a Bermuda charitable believe in with billions of pounds of property and failed to pay out taxes on them. Brockman’s lawyers explained the belief owns entities that command the computer software agency, Reynolds and Reynolds, which is valued at $5 billion.

The IRS hasn’t alleged that “any one has taken any motion to conceal, dissipate, transfer, or in any way diminish the benefit of Reynolds,” Brockman’s attorneys wrote in a court submitting. “In other text, dependent on the IRS’s principle that Mr. Brockman is the proprietor of Reynolds, there are assets value a numerous of the asserted tax liability that are and will continue being offered in the United States.”

That signifies the IRS are not able to say that “collection would be jeopardized” if it prevails on the taxes owed, Brockman’s attorneys claimed.

A Justice Division spokeswoman declined to comment to Automotive Information over and above court filings. The federal government experienced not nonetheless responded to the lawsuit as of Monday.

Brockman’s attorneys did not react to a request for remark by Automotive Information.

The case is Brockman v. United States of The united states, 22-cv-202, U.S. District Court, Southern District of Texas (Houston).

Automotive Information Reporter Lindsay VanHulle contributed to this report.