"Judge set to rule in dispute over Seal tax assessment"
THE BATON ROUGE STATE TIMES 
March 28, 1986

NEW ORLEANS _ A federal judge today took under advisement a dispute
over the Internal Revenue Service's tax assessment against the
property of slain drug smuggler/informant Adler "Barry" Seal.
          U.S. District Judge Martin Feldman heard seven witnesses Thursday
and took a little more evidence today before he recessed the hearing.
          Feldman was to rule this afternoon.
          Witnesses have testified that Seal continued his drug trafficking
operation even after he began cooperating with federal agents.
           Also, they said Seal used aliases and an intricate web of holding
companies in his drug dealings, and had a Honduran passport signed
Joseph C. Warren when gunmen killed him in Baton Rouge Feb. 19.
           Feldman criticized clashes between prosecution witnesses and
defense attorneys, who are fighting over a $29,487,718 IRS jeopardy
tax assessment that has left Seal's estate in limbo.
           Feldman must decide whether the IRS was justified when it seized
$1.5 million in property from Seal in a jeopardy assessment. His
judgment will be final.
           A jeopardy assessment action is taken when a taxpayer is
suspected of hiding assets from the government.
          State Police Lt. Bob Thomasson said intelligence reports on Seal
from files dating back to 1972 indicate he headed his own
organization.
         "Mr. Seal was suspected of being the head of a large
drug-smuggling organization consisting of some 60 people operating in
six or seven states and several foreign countries," Thomasson said.
          The reports indicate Seal's organization continued drug
trafficking activities for profit while Seal worked as an undercover
informant for the DEA, he said.
           Seal most often used the alias "Bill Elders" in business
dealings, but also was known as "Gordo" and "Thunder Thighs" to
members of his organization, Thomasson said.
           Thomasson said he first learned of Seal's relationship with
Florida-based DEA agents Robert Joura and Earnest Jacobson in 1984,
and that at least two clandestine operations they conducted in the
middle district indicated "Seal was not being controlled by the DEA.
          "If he was cooperating with the government, he was not being made
to cooperate according to the rules and regulations of the DEA," he
said.
          In lengthy cross-examination, attorney Barry L. Lieberman accused
Thomasson and the state police of having a "strong distaste" and a
bias against Seal because of his stealth as a drug trafficker and
resourcefulness as a federal witness.
         "Did you feel he got off too lightly?" Lieberman asked.
        "You're asking for my personal opinion?" Thomasson said.
        "He's trying to impeach you," Feldman said. "He's trying to
prove you're lying."
         Feldman later told Lieberman to sit down when Lieberman objected
to the judge's own questions posed to Thomasson.
        "I don't need you to object to my questions; I'm perfectly
capable of judging my own questions," he told Lieberman.
        Thomasson said he gave IRS officials "everything I had" on Seal
when they began looking into his case in November 1985.
         Revenue Agent Elmer Holmes said his decision to recommend a
jeopardy assessment in Seal's tax case was based on transcripts of
Seal's testimony at a Miami drug trial and before the President's
Commission on Organized Crime concerning profits from his drug
trafficking activity.
          The decision also was based on conversations with Thomasson and
Seal's guilty plea to a bank fraud charge that involved money
laundering.
         "In this particular case, he had been convicted twice and he had
pleaded guilty in the Middle District of Louisiana to bank fraud,"
Holmes said. "The testimony I had read from the trial in Miami
indicated he had underreported his income by some $14 million ... Lt.
Thomasson seemed to indicate to me that he was transferring assets."
          Holmes said IRS agents have linked property to Seal that was not
cited on his financial statements submitted to federal officials.
         That property includes a 220-foot converted mine-sweeper vessel in
San Francisco.
          Holmes said Thomasson also provided the IRS with information that
an airplane owned by Seal was transferred to a South American country
and the "Laura Lea," an 85-foot boat, was sold to the Cayman Island
corporation Ram Ltd.
         The plane later was seized by IRS agents Feb. 3 in Mena, Ark.
         Other IRS officials said while Seal was cooperative, he did not
 volunteer information about his assets and that linking some of the
 property to Seal was complicated.
          Agent Henry McKinnell said Seal would not let IRS agents enter
 his office during a massive seizure of property Feb. 3 until they had
 secured a writ of entry.
          "At this time, he let us in and I noticed an odor of burning
 paper," McKinnell said. "He said he had papers and documents
 relating to local law enforcement officials, apparently evidence of
 wrongdoing, that he didn't want to disclose yet."
          Other property seized by the IRS included Seal's home and its
 contents, land in several parishes, two shrimp boats and aircraft
 stored in Louisiana and Arkansas.
          IRS Agent Frank Hestel said agents had trouble tracing a Grumman
 Albatross plane seized in Mena, Ark., to Seal because it wasn't
 registered in his name.
          He said the shrimp boats "Laura Lea" and "Captain Wonderful" are
 listed as property of a Cayman Islands company that was traced to a
 company in Panama that was listed on a copy of a stock certificate
 that was found in the white Cadillac Seal was driving the night he
 was shot to death.
          IRS officials seized the property after accusing Seal of
 "designing to quickly place property beyond the reach of the
 government... " in a letter dated Feb. 4.
          Attorneys for the Seal estate have said Seal paid his taxes for
 1981, 1982 and 1983 _ the years during which IRS officials claim Seal
 made more than $22 million smuggling cocaine.
          Lawyers have said Seal's net worth was estimated at $1.2 million
 on a financial statement he was required to file with federal
 probation authorities.