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United States v. Heptner
Citation:
2016 WL 3344564 (M.D. Fla. 2016)Facts
On February 26, 2004, James Heptner filed untimely federal income tax returns for the years 1993 through 1996, and 1999 through 2001, but he failed to pay the taxes he reported on those returns. Heptner made installment payments to the IRS from 2005 to 2009, but he fell behind. Heptner practiced law from 1984 until 2001. He became employed by Damien Freeman around 2002. Freeman owns various corporations including ITS Billing, Inc. Freeman paid Heptner approximately $50,000 per year. Freeman was Heptner’s direct boss and they formed a friendship. Freeman sympathized with Heptner and agreed that his company, ITS Billing, would provide him a loan to buy the house in June 2005. Eventually, ITS Billing sued Heptner to compel him to deliver a signed purchase money note and mortgage. The state court found that Heptner’s representations regarding receiving the purchase money for the property as compensation are neither reasonable nor credible. The state court ordered judicial sale of the property and Heptner refused. On May 8, 2015, the IRS filed the action to reduce to judgment unpaid federal income taxes owed by Heptner and to foreclose federal tax liens.
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