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Q Was it your understanding that he would
tell you when the notes should be repaid
under the tax law?
A Well, I was counting on his advice.
Q * * * What was your understanding with
regard to those quarterly payments?
A I didn't have any knowledge or
understanding of that. I was just relying
on the advice of my CPA.
Q And, in fact, was that the course of
action you followed throughout 1987, '87,
[sic] '88, '89 and until the present?
A That's correct.
On cross-examination, petitioner admits that he never
received any specific advice regarding the taxability of
the loans. Petitioner testified as follows:
Q Mr. Garcia, I -- we would just like to know
what your position was, whether you felt that you
were supposed to pay tax on distributions from
those loans you took in 1986 when you signed your
return.
A I really don't know because, again, I was
just counting on the advice of my CPA.
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