This section contains the nature of the case and procedural background.

McNulty (D) won the Irish Hospitals Sweepstakes. He collected 50,000 Irish pounds or $128,410. His silent partner, the Internal Revenue Service, came knocking on the door and demanded their cut of the action. D decided he didn’t want to pay and put the money in a secret bank account on the Island of Jersey. D was convicted of income tax evasion and remains in federal prison. The government then prevailed in a civil action on January 23, 1978, for the collection of the taxes, penalty, and interest. D has no other funds or assets with which to satisfy the civil judgment other than the monies in the Island of Jersey. The government then moved for an order directing D to repatriate his monies under the authority of 26 U.S.C. 7402.

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