In a lawsuit filed last month, Brockman’s lawyers sought to undo the jeopardy assessment and denied he’s hiding assets. “There is no jeopardy,” they wrote. “The IRS’s actions were baseless and wholly unreasonable, and must be immediately abated.”
Brockman is separately contesting the amount of the jeopardy assessment in Tax Court.
A spokesperson for the Justice Department declined to comment, and an attorney for Brockman didn’t immediately return requests for comment.
Dementia Question
The IRS battle is unspooling before U.S. District Judge George C. Hanks, who is separately weighing whether Brockman’s dementia leaves him incapable of helping defend against a 39-count indictment. Hanks, who heard arguments on Brockman’s competency in November, is expected to rule in the coming weeks.
But now the judge also must wade through hundreds of pages filed by the Justice Department, offering far greater detail about Brockman’s sprawling offshore trust network spanning Bermuda, the Cayman Islands, Nevis, Switzerland, Singapore, Guernsey, Jersey, the British Virgin Islands, and the Isle of Man.
Brockman avoided reporting $2.7 billion in income through an “own nothing, control everything” strategy that hid assets behind offshore trusts and nominees, according to the filing.
“When Brockman is confronted with government action against him, his assets, his entities, or his foreign bank accounts, he responds by opening new foreign accounts, creating new mirror companies to hide his assets, and moving control to other foreign entities in well-known tax havens,” U.S. lawyers wrote.
They cited litigation that succeeded in transferring control of a Brockman family charitable trust, worth billions of dollars, from Bermuda to the Cayman Islands, “where a U.S. judgment for taxes may be unenforceable.”
The filings also give new insights into Brockman’s investments, which prosecutors say included stakes in approximately 11 Vista Equity Partners funds between 2000 and 2018. Vista founder Robert Smith avoided prosecution by admitting tax crimes, paying $139 million, and cooperating with the government against Brockman.
