Joe Francis, chief executive of the company that produces the “Girls Gone Wild” series of racy videos, has sued the Internal Revenue Service for freezing his assets after a judge approved a plea bargain deal in his tax case.

Francis pleaded guilty in October to two misdemeanor counts of filing false tax returns, and in early November U.S. District Judge S. James Otero sentenced him to time served. Francis had been held without bail for nearly a year in the tax case. Under the plea deal, Francis agreed to pay restitution, back taxes and interest totaling $249,705, plus a fine of $10,000.

In addition, he agreed to plead guilty to two misdemeanor counts in exchange for having the charges dropped. Francis claims that his CPA, former Mantra Films CFO Michael Barrett, conspired with two others to embezzle millions of dollars from the company and then contacted the tax authorities in order to win a whistleblower award from the IRS.

However, shortly after the judge accepted his plea deal, the IRS filed a lien for $33,819,087.14 for three years of back taxes, from 2001 to 2003 (see IRS Files $34M Lien Against ‘Girls Gone Wild’ Founder).

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.

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