'Girls Gone Wild' Founder Joe Francis Sues IRS for Retaliatory Tax Lien

Web CPA reports this morning that Girls Gone Wild founder Joe Francis has filed a lawsuit against the IRS for illegal collection activities:

[S]hortly after the judge accepted his plea deal [he pleaded guilty to two misdemeanor counts of filing false tax returns and was sentenced to the nearly year in prison that he had already served and required to pay $250,000 in back taxes, interest, and penalties], the IRS filed a lien for $33,819,087.14 for three years of back taxes, from 2001 to 2003.

Francis claims in his lawsuit that the IRS moved to freeze his assets within three hours after he left the courtroom, according to TMZ.com. He claims that the only circumstances under which assets can be frozen are if the taxpayer is preparing to flee the country, if the taxpayer is attempting to move assets out of the reach of the IRS, or if the taxpayer appears to be going bankrupt.

Francis contends that the only reason the IRS would be trying to freeze his assets is revenge and he is asking the judge to unfreeze his bank account.

The Tax Lawyer's Blog picks apart Mr. Francis's argument.  In unrelated news, Mr. Francis has threatened to sue Gawker for bestowing on him its "Douche of the Decade" award.

Prior TaxProf Blog coverage:

• Taxes Gone Wild: Joe Francis Indicted on Tax Charges (4/12/07)
• Founder of "Girls Gone Wild" Pleads Not Guilty to Tax Evasion Charges, Says "IRS Gone Wild" (7/23/08)
• "Girls Gone Wild" Founder Seeks New Counsel in Tax Evasion Case (1/28/09)
• Tax Lawyer Strikes Back at "Girls Gone Wild" Founder Joe Francis (1/30/09)
• Joe Francis to Use "Deductions Gone Wild" Defense in Tax Evasion Trial (8/27/09)
• 'Girls Gone Wild' Founder Joe Francis Cops Tax Plea (9/24/09)
• 'Girls Gone Wild' Founder Joe Francis Gets Time Served in Tax Case (Nov. 8, 2009)
• Tough Week for 'Girls Gone Wild' Founder Joe Francis: $34m Tax Lien, Mocked by Stanford Band (Nov. 20, 2009)
• Tax Whistleblowers Gone Wild (Nov. 30, 2009)