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The Internal Revenue Service has collected more than $3.2 billion in back taxes, interest and penalties from participants in a single tax shelter, including $100 million from one taxpayer and $20 million each from 18 others, the agency said today.

The Internal Revenue Service has collected more than $3.2 billion in back taxes, interest and penalties from participants in a single tax shelter, including $100 million from one taxpayer and $20 million each from 18 others, the agency said today.

The total take for the agency from participants in the shelter is expected to top $3.5 billion ultimately, making this by far the largest such program ever, IRS Commissioner Mark W. Everson said.

Everson said that nearly 1,200 of the approximately 1,800 taxpayers — mostly wealthy individuals but including a few corporations — who made use of the shelter known as “Son of BOSS” had agreed to the settlement. Another 200 were barred from the program because they had also been involved in marketing the shelter.

“The IRS will vigorously pursue” the remaining 400 “who did not come forward. We have their names. We are going to give them special treatment, putting them at the head of the line for audits,” Everson said, adding that the agency “will litigate the matter vigorously in court” if necessary.

The $3.2 billion is cash that the IRS has in hand, Everson said. Neither he nor other IRS officials would give names or discuss details of individual cases, but Everson did say that “some people have had to sell their villas or their yachts and come up with the cash to cover their debt to the government.”

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