Ragnhild A. Westby - Page 19

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               At one point during petitioner’s testimony, the following              
          exchange occurred between the Court and petitioner:                         
                    THE COURT:  All right.  Now, let me ask another                   
               question.  You’re a lawyer with a license at risk.  You                
               knew you had an obligation to file a return and that                   
               that return had to be filed timely or you were going to                
               have a problem.                                                        
                    THE WITNESS:  Right.                                              
                    THE COURT:  Why didn’t you protect yourself                       
               better?                                                                
                    THE WITNESS:  I suppose I’ve asked myself that a                  
               million times.  It –- I think part of –- when I think                  
               back on it, I was very used to going ahead and doing                   
               things, but, in this particular situation, [Rowe] had                  
               paid in no money for the self-employment tax, and it                   
               appeared that he was going to have a liability on his                  
               side of the fence.  And my push to get done and his                    
               reluctance and his being the primary contact with Aunan                
               was not a good combination.                                            
                    But, you know, all excuses aside, I have to be                    
               responsible for myself.  And I did not do in my own                    
               mind, which is –- what I should have done is -- I did                  
               not fire him.  I did not report him.  And I did not go                 
               to my old accountant and file a separate return, no                    
               matter what the economic consequences.                                 
          VIII.  October 17, 2000, Order                                              
               After respondent filed his status report and supplemental              
          status report (SSR) describing the results of the parties’                  
          posttrial efforts to resolve outstanding issues, we issued an               
          order dated October 17, 2000, which (1) listed the Schedule C               
          income and deduction amounts remaining in dispute after                     
          respondent’s further concessions, (2) ruled upon various                    
          exhibits, the admissibility of which had been left open at trial,           






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