The IRS alleges that Robert Brockman owes $1.45 billion in unpaid taxes.

A billionaire facing the largest tax-evasion case against an individual in U.S. history complained that the Internal Revenue Service emptied his wife’s bank account as it tries to collect $1.45 billion he allegedly owes in taxes.

Robert Brockman, 80, told the U.S. District Court in Houston that he’d offered to set aside $1.45 billion from his family’s trust in Bermuda while he challenges the IRS’s claims about his tax debt.

“It is unfathomable that the government may turn away from a proposal that would make full collection of its asserted tax liability possible, while the IRS instead continues in its efforts to grab far lesser amounts from Mr. Brockman, his wife, and other third parties,” Brockman’s lawyers wrote in a court filing.

The government claims its actions have been proper. Brockman pleaded not guilty to tax charges against him.

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