No, not the television quiz show. But let’s take “dissipation of assets” and “removal of property” for $200K, Alex, and watch Judge Nega spin the wheel for Christopher A. Bibby, the enterprising lead player in the eponymous 2013 T. C. Memo. 281, filed 12/12/13.

Chris shows his buccaneering spirit by claiming $213K in withholding (to which he is admittedly not entitled) and getting a $203K refund, which he proceeds to disburse thusly: “Petitioner admits spending the refunds for the following items: (1) $32,133.88 for a used car; (2) $25,270 for offerings and tithes to his church; (3) $21,077 for wedding and honeymoon expenses; (4) $61,815 on home repairs; (5) $9,482.50 for tax return preparation and filing; (6) $1,955.66 on furniture purchases; and (7) $36,365 for various items such as food, clothing, and bill payment. Petitioner admits transferring his interest in his personal residence to a property holding company wholly owned by petitioner and his wife. Petitioner also made a $25,000 loan to Diamond & Associates, in repayment of which Diamond & Associates quitclaimed three properties to petitioner, which petitioner subsequently transferred to EMG, LLC, a separate business entity wholly owned by petitioner and his wife.” 2013 T. C. Memo. 281, at pp. 2-3.

Ya gotta like a guy who steals from us all to give to his church. By your leave, Chris, I’ll decide to which religion, if any, I give my money. And to whom I’ll give wedding presents.

Anyway, Chris diddles with IRS about collection alternatives, while failing to disclose wage and pension information, and not conveying back the real estate to himself alone.

IRS loses patience and hits Chris with a jeopardy levy, which Chris petitions.

Judge Nega elaborates on Section 6851 and the regulations thereunder: “The existence of one or more of the following conditions supports a determination that collection of the tax is in jeopardy: (1) the taxpayer is or appears to be designing quickly to depart from the United States or to conceal himself or herself; (2) the taxpayer is or appears to be designing quickly to place his, her or its property beyond the reach of the Government by removing it from the United States, by concealing it, by dissipating it, or by transferring it to other persons; (3) the taxpayer’s financial solvency is or appears to be imperiled. Sec. 1.6851-1(a), Income Tax Regs.; sec. 301.6861-1(a), Proced. &Admin. Regs.” 2013 T. C. Memo. 281, at p. 7.

Chris is a prime candidate for jeopardy: “Petitioner incorrectly claimed and received large tax refunds and then proceeded to freely spend from those refunds. Petitioner also transferred certain real property received in satisfaction of a loan to Diamond & Associates to EMG, LLC, and then jointly to himself and his wife. We find that these facts justify the determination to sustain the jeopardy levy because petitioner was quickly dissipating the funds or otherwise attempting to put them beyond the reach of respondent [IRS] by transferring funds to third parties. It should also be noted that petitioner has not disputed his tax liabilities. Petitioner did not fully cooperate with the settlement officer’s reasonable information requests about sources of unreported income and the transfer of certain real property other than to petitioner’s direct ownership.” 2013 T. C. Memo. 281, at p. 9.

Now readers of my blog (that stalwart company) may remember my abbreviated discussion of jeopardy levies in connection with Lee Ang’s trial, which I did not attend. See my blogpost “The Answer”, 12/10/13.

But this opinion from Judge Nega is the whole story; in the immortal words of Dan Rowan and Dick Martin from long ago, “you can bet your Bibby.”