Samuel Wyly’s lawyer, fighting a $2.2 billion claim by the Internal Revenue Service, told a skeptical judge that his client’s tax planning was “aggressive but not illegal,” Bloomberg News reported yesterday. The IRS is suing to recover unpaid taxes, interest and penalties on money held in offshore trusts from 1992 to 2013 by Sam Wyly and his late brother Charles, who got rich building businesses including the Michaels Stores Inc. arts-and-crafts chain. The Dallas bankruptcy judge heard closing arguments yesterday. Wyly and his brother’s widow, Caroline “Dee” Wyly, filed for bankruptcy protection after the Securities and Exchange Commission won a fraud lawsuit against the brothers in Manhattan in 2014. Charles died in a car accident in 2011. The SEC verdict also prompted demands for 22 years’ worth of back taxes and penalties by the IRS, which the agency said was related to the securities fraud.
