- 32 -
Glen & Graf or the nature or extent of any advice that
Mr. Glen may have provided to petitioners with respect
to the returns.
Petitioner testified in general terms that he relied
upon the advice of his accountant to establish and
administer the qualified plan, and that he relied upon
his accountant's advice with respect to his personal
income tax returns for 1990 and 1991, and with respect to
the preparation of annual reports on behalf of the plan.
However, petitioner's testimony regarding the advice he
received from Mr. Glen about the subject loans was vague
and contradictory. On the one hand, he testified on
direct examination that Mr. Glen advised him not to make
any payments on the loans:
Q Now, Dr. Garcia, did you make any
payments -- your -- did you make any
payments on the loans which have been
entered into evidence other than the
payments -- the partial payment that was
made in 1988, I believe, and which is shown
in the stipulation, and then the payment on
Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 NextLast modified: May 25, 2011