"Girls Gone Wild" founder claims IRS out to get him

"Girls Gone Wild" founder Joe Francis may have been on the naughty list this year -- and he's making a federal case out of it.

Francis has filed a federal lawsuit claiming that the IRS has targeted him unfairly for enforcement. According to TMZ, the suit alleges that the IRS unlawfully froze $33 million of Francis' assets hours after his plea agreement with prosecutors relating to tax evasion charges.

The initial charges against Francis alleged that Francis claimed over $20 million in phony business expenses on his corporate tax returns for 2002 and 2003. Reportedly, those expenses include $3.8 million for a Mexican vacation home. Francis was also accused of transferring millions of dollars offshore in order to evade taxation. If convicted, he had faced a maximum of 10 years in prison and fines of up to $500,000.

Francis eventually struck a deal with prosecutors in the case. Under the agreement, Francis was credited with 301 days already served and sentenced to one year of probation. He pleaded guilty to two misdemeanor counts of filing false tax returns and one count of bribing Nevada jail workers.

The agreement required Francis to resolve his outstanding tax issues with the IRS. The IRS alleges that he did not make an effort to pay his taxes and liened Francis for nearly $34 million ($17.7 million in 2001, $11.2 million in 2002 and $4.9 million in 2003). Francis claims that the IRS is merely seeking revenge.

Through his attorneys, Francis claims that the only circumstances under which the feds can freeze a taxpayer's assets before getting a judgment is if it looks like the taxpayer is about to flee the country, hide assets or otherwise make assets unavailable to the IRS. Francis must believe that his behaviors don't qualify despite the allegations that he might declare bankruptcy to avoid satisfying the judgment.

While the IRS won't comment publicly on a taxpayer's case, it's worth noting that the criminal case against Francis would have proceeded separately from the attempt to collect the unpaid taxes. The IRS may, after following certain procedures, "seize" assets if a taxpayer does not respond to attempts to collect. Most commonly, this involves liens against real property, levying bank accounts and garnishing wages.

This lawsuit is not the first time that Francis has played the victim card. When he entered his "not guilty" plea initially, he claimed that he was the victim of a scheme by his accountant to profit from the IRS whistle-blower program.

With all of this legal activity, you can bet on at least one person having a great holiday: Francis' lawyer.