- 34 - 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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