Federal prosecutors are trying to seize a $15 million fishing compound in Colorado and $77.9 million in a Swiss bank account linked to an alleged fraud by former Reynolds and Reynolds Co. CEO Robert Brockman, who was indicted last year in the biggest U.S. tax-evasion case ever against an individual.

Beyond claims that he failed to report $2 billion of income, Brockman is accused of using a foreign company he secretly controlled to buy secondary debt in his own software firm, Reynolds and Reynolds, at a deep discount in 2009. Prosecutors claim that assets tied to the debt fraud are subject to forfeiture, including a fishing lodge he developed on the Frying Pan River, according to U.S. court filings in March.

The targeting of cash in Switzerland’s Mirabaud Bank and 143 acres where Brockman has spent parts of his summers fly fishing for rainbow and brown trout are the only known attempts to take his property since he was indicted in October. The billionaire may be forced to turn over some assets even if a judge agrees with claims by Brockman’s attorneys that he isn’t competent to stand trial or he is found not guilty, said Peter Hardy, an attorney at Ballard Spahr who edits a blog about money laundering.

The government only has to show an asset was “the product of tainted funds” to take it in a civil forfeiture proceeding, said Hardy, who isn’t involved in the case.

In an asset-seizure affidavit filed by Internal Revenue Service special agent Ted Lair, the government alleges Brockman laundered some of his illicit proceeds through funds managed by Vista Equity Partners, a private equity firm run by Robert Smith.

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