Wesley Snipes, the actor who fought an unsuccessful battle against the Internal Revenue Service over his unpaid taxes and ultimately served a nearly three-year prison term, is now in a fresh dispute with the agency.

Snipes has reportedly petitioned the U.S. Tax Court to allow the actor to enter the IRS’s Fresh Start initiative and lower the amount of unpaid taxes that the IRS is assessing him. The IRS denied Snipes’ offer to pay $842,000 and is instead demanding the actor pay $17.5 million, according to Bloomberg BNA.

Snipes was convicted in 2008 on three misdemeanor counts of failing to pay his taxes for three years for 1999, 2000 and 2001, although he was acquitted of felony charges (see Snipes Sentenced to Three Years for Tax Charges). He had followed the advice of a tax protester organization that claimed income taxes were illegal, but ultimately acknowledged his errors.

Snipes served his prison term from December 2010 to April 2013, according to Forbes. The IRS issued him a $24 million tax lien in April 2013, assessing his unpaid taxes for 1999 to 2006 at $24 million. This past February, the IRS estimated his reasonable collection potential to be just $6.4 million, however. On the day that a conference call was scheduled with the IRS, Snipes claims the IRS increased the collection potential to over $18 million. The figure was based on some recent acting jobs that Snipes has landed, including a starring role in the NBC series "The Player."

He objected to the IRS’s estimate, and the IRS is now asking for $17.5 million. But Snipes’s attorneys are disputing that amount, saying, “Petitioner is trying to put his life back together after being led astray by unscrupulous advisors, and he desperately needs the fresh start which Respondent's ‘Fresh Start Initiative' offers.”

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