If you are really stubborn, you can hold out on paying the IRS for a really long time. With luck, the statute of limitations on collection might bail you out. If the IRS does not collect within ten years of the time that it assesses a tax, you are home free. There are complications and ways in which the ten-year clock can be stopped, so I don’t recommend this sort of course for the faint of heart. Glen Stoll is not faint of heart. He believes that all IRS assessments against him are wrong and looks forward to the day of total vindication, which may not come until Jesus returns. Mr. Stoll recently had a setback in his quest for vindication in the United States District Court for the Western District Court of Washington (the state). Judge Thomas Zilly ruled that the IRS assessment of tax liabilities for the years 2001-2008 with interest through December 13, 2024, totaling $1,265,461.89 is “reduced to judgment”. The ten-year clock will no longer tick, because it has been smashed. It is not an assessment anymore. It is a judgment.
Foreclosing Liens
Then there is the matter of property in Marysville, Washington. The IRS was seeking to foreclose liens on the property. That added defendants to the case – Stoll Family Trust, Director of the Family Defense League and Snohomish County. Director of the Family Defense League, which is also known as Family Defense League and a couple of other things, is a corporation. According to the Washington Secretary of State website, the nature of its business is “A Washington Acknowledged Corporation Sole of the Church”. The Governor of the corporation is Glen Stoll. There is also a note that the corporation was administratively dissolved on June 3, 2023. I asked Glen Stoll about the dissolution. He told me that he has several years to fix that. It was a sort of administrative glitch. The state stopped allowing paper filings, and the people he had helping him with it are not internet savvy.
The Stoll Family Trust had been amended in 2005 to provide that on the death of Glen’s parents, Richard and Mary Stoll, property including the Marysville home would be distributed among Glen and his two siblings with the Marysville home going to Glen. If Glen disclaimed, the property would instead be distributed to the Director of the Family Defense League. Glen Stoll disclaimed in 2012. Although there was never a formal deed to the Marysville home, he has been living there, although he does not receive mail there or treat it as his legal address.
Attorney Problems
The case was complicated by the lack of attorneys for the trust and the corporation. Glen Stoll told me he had a great difficulty finding attorneys. Among his efforts was some sort of AI program that contacted 600 attorneys, none of whom were interested. An individual can represent themselves, but entities need to be represented by an attorney. Stoll believes many of our problems come from two sources. One is organized religion. I think he is referring there to denominations. The other is “unionized attorneys”. That is a reference to bar associations.
Finally Alan Stuart Richey agreed to represent the Stoll Family trust. I found this a surprising enough choice that I gave Kent Hovind a call about it. Richey represented Hovind in his 2006 trial and Hovind was very dissatisfied with the job he did. Hovind told me that he thought that Richey was a wolf in sheep’s clothing. Richey was named as a defendant in Kent Hovind’s half billion dollar lawsuit in 2020. Glen Stoll was aware of this, but nonetheless found Richey fine to work with. I have not been able to reach Richey.
The Ruling
There were a few elements to the ruling. First off, the judge denied Stoll any further extensions of time. To the extent that the Director of the Family Defense League holds an interest in the property, it does so as Stoll’s alter ego. This was a default judgment, as the corporation never had an attorney. Even though there was never a deed issued, the Stoll Family Trust is no longer the “true owner” of the property as the trustee was required by the terms of the trust to distribute it. That makes it irrelevant whether the trust was Stoll’s alter ego. The Government had previously entered into a stipulation with Snohomish County that property taxes were ahead of the federal lien.
The final word is: “The Government is entitled to judgment as a matter of law concerning the amount of Stoll’s tax liability, including interest, penalties, and statutory accruals, and its right to foreclose on its tax liens against the Subject Property.”
Issues Not Addressed
When I spoke to Glen Stoll he indicated that he will be appealing. He was a bit incensed at Judge Zilly, who he didn’t think paid close enough attention. He attributed some of the problems to the judge’s advanced age, which Stoll exaggerated a bit, He did not think the judge paid attention to his arguments. Generally speaking Stoll wished people would read and listen more. In various documents, Glen Stoll wrote fascinating arguments that I would have loved to see Judge Zilly address
Judge Zilly did comment on Stoll’s statements that he had never run an ‘abusive tax promoter business’ of any kind. The judge noted Stoll’s guilty plea in 2021, which I covered here.
Stoll argues that he has no taxable income, because he is a volunteer to the church, which he effectively controls. He does not need any income because the church takes care of his needs. He had not been filing returns, because he had no income. The IRS created substitutes for returns for 2001-2008, which is where the assessment comes from. He responded with zero returns. It would have been interesting to flesh that issue out more.
In an appendix to his memorandum of fact, argument and law, Stoll includes a bit of an autobiography which includes:
“For nearly all my adult life I have been doing charitable church mission work without any direct payment for my personal gain. All compensation for my services, if any at all, goes directly into the ministry. In turn, the ministry provides me with a place to live, for other basic necessities of life, and for the basic support of my family. I own nothing and have no personal income.”
And then there is this:
“By 1999, I had travelled seven times across the U.S./Mexico boarder (sic) on Medial Missionary journeys. During each of those crossings I formally identified myself using my Church issued passport as a Citizen of the Kingdom of Heaven and Resident of the Church”
If you are interested in a passport or drivers license from the Embassy of Heaven you can check this link out. I don’t recommend it.
Reaction
I reached out to Paul Hansen, Kent Hovind’s co-defendant in 2015 and the brains behind his over half-billion-dollar lawsuit. In the past Hansen has been very critical of Stoll’s work. Hansen’s legal theories tend to be based on forcing government agents to prove that they have jurisdiction. I asked Hansen if his opinion of Stoll had changed since the critique he wrote in 2017. Hansen indicated that he could add to the critique.
Neil Bass of the Bass Tax Group has a nice piece on the opinion titled The Long Game of Glen Stoll: How a Tax Scheme King Finally Lost His Kingdom. He concludes:
“In an era where tax enforcement is becoming increasingly aggressive, Glen Stoll’s saga is a case study in how long a determined individual can game the system, and what it takes to finally bring them down.
But the damage is not limited to one man. For years, his schemes lured desperate clients seeking tax salvation. They, too, now face audit, penalty, or worse.
As federal agents prepare the paperwork to sell off the last symbol of Stoll’s financial fantasy, one can’t help but see the irony: a man who built a career helping others “protect” assets couldn’t even protect his own front door.”
I don’t think we actually are in an era of more aggressive tax enforcement. The taxes that may now be collected from foreclosing on property determined to be effectively owned by Glen Stoll are for the years 2001 to 2008. In cases like this we are seeing the effect of decades of lax enforcement..
Read the full article here
