Paul A. Bilzerian - Page 16




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          $4 million of taxable income was omitted from the return.                   
          However, petitioner also testified that he received the return on           
          October 15, 1987, and, due to requests for extension filed by               
          petitioner, the return was due on that same day.  Petitioner                
          stated that he could not recall whether he called Mr. Norris to             
          question the accuracy of the return on October 15, 1987, nor                
          could he recall discussing with Mr. Norris at any time the $2               
          million discrepancy between the estimated payment by petitioner             
          and the tax liability as reported on the original 1986 return.              
          In his criminal trial, petitioner testified that he was delighted           
          that the return he received from Mr. Norris showed a tax                    
          liability of only $3 million, and he never challenged the                   
          accuracy of the return.                                                     
               Petitioner is a well-educated individual who was involved in           
          trading securities for several years prior to 1986.  He was                 
          provided with a schedule from Peat Marwick outlining petitioner’s           
          estimated tax liability for 1986, and the schedule specifically             
          identified the $4 million in gains from the purchase and sale of            
          the Hammermill stock.  Petitioner accepted the return as prepared           
          by Mr. Norris without questioning its accuracy or inquiring as to           
          the approximately $2 million difference between the tax liability           
          stated on the return and the amount paid as an estimate of the              










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