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Additionally, Henry did not provide any other reasonable
explanation as to why Warner-Lambert decreased the final purchase
price paid for IMED from $480 million to $465 million. In these
circumstances, Henry’s plea of ignorance does not ring true.
Henry’s involvement at the top level of IMED and in the Warner-
Lambert negotiations undermines his plea of ignorance, and we so
find. Cf. United States v. Aleman, 728 F.2d 492, 494 (11th Cir.
1984); United States v. Jewell, 532 F.2d 697, 700 (9th Cir. 1976)
(defining “‘wilful blindness’”).
In Cramer v. Commissioner, 101 T.C. 225 (1993), we decided
Cramer, Boynton, and Monaghan were liable for additions to tax
for negligence because they deliberately disregarded rules and
regulations. In that opinion, it was indicated that Boynton was
aware of the potential risk that the Commissioner might challenge
the treatment of the stock option proceeds because of his close
friendship with Cramer and Monaghan. "Cramer and Monaghan would
have had to have actively misled Boynton for him to have been
unaware of the risk associated with his 1982 tax return
position", and this event was unlikely to have occurred "in view
of * * * [the taxpayers'] friendship and business relationship".
Id. at 253.
Although Cramer referred to Henry as "the one outsider" on
IMED's board, he met with Henry on a daily basis and occasionally
went out to dinner with him. Also, Henry was involved in the
negotiations regarding the sale of IMED to Warner-Lambert and was
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