- 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 the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011