Billionaire decries IRS seizing wife’s bank account in lien case

The billionaire facing the largest U.S. tax-evasion case against an individual slammed the Internal Revenue Service for emptying his wife’s bank account as it seeks to collect $1.45 billion from him.

Robert Brockman claimed in a Houston federal court filing that the IRS seized the money Monday and shunned an offer by his family’s Bermuda trust to set aside $1.45 billion while he contests the agency’s civil claims. The seizure occurred the same day U.S. lawyers urged a judge to reject the trust’s proposal to relax liens on Brockman’s property and assets, the filing says.

“It is unfathomable that the government may turn away from a proposal that would make full collection of its asserted tax liability possible, while the IRS instead continues in its efforts to grab far lesser amounts from Mr. Brockman, his wife and other third parties,” Brockman’s lawyers wrote Wednesday.

brockman-robert-masked.jpg
Robert Brockman, the software executive charged in the largest-ever tax case against a U.S. individual, departs from a competency hearing at the federal courthouse in Houston, Texas.
Mark Felix/Bloomberg

Brockman wants a judge to lift the IRS’s so-called jeopardy assessment, which allows immediate collection when taxpayers are “designing quickly” to move assets beyond the government’s reach. The government said in its filing that its jeopardy assessment shouldn’t be lifted based on a letter from the Bermuda trust.

But the government said the assessment is proper against Brockman, 80, who pleaded not guilty after his 2020 indictment for allegedly using the trust to evade taxes on $2 billion in income. U.S. prosecutors and the government’s civil lawyers said Brockman secretly controlled the trust, making him liable for taxes.

“Brockman continues to view and use his offshore entities as his own personal bank accounts,” U.S. lawyers said Monday in a filing, citing yacht and real-estate purchases. “Now, when Brockman needs funds to secure the collection of his personal taxes, he uses the trust.”

In the criminal case, Brockman’s lawyers claim he has dementia and can’t understand the charges. He has denied wrongdoing. U.S. District Judge George Hanks oversaw an eight-day hearing on his competency in November but still hasn’t ruled. Hanks also has the civil case.

Bloomberg News
Tax Tax evasion IRS Trusts
MORE FROM ACCOUNTING TODAY