- 16 - $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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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