- 28 - 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 wasPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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