Texas billionaire Robert Brockman, who is currently facing criminal tax charges, sued the government Thursday to halt a special procedure for immediately assessing more than $1.4 billion in taxes, penalties, and interest against him.
The"jeopardy assessment” involves taking immediate action under tax code Section 6861(a) when delay would jeopardize the IRS’s ability to assess or collect taxes. Brockman is also challenging a jeopardy levy under tax code Section 6331, which allows the IRS to start collecting on taxes if it finds that collection is in jeopardy.
Brockman said Thursday that the agency has baselessly ...