- 22 -
THE COURT: In ‘95, you filed that return sometime
in, what, in ‘96.
MR. PRATT: It says here, in ‘96.
THE COURT: Right. So, and, normally, you would
file a return, by the way, in April.
MR. PRATT: Oh, I understand that, sir.
THE COURT: And here, you filed it not in April, but
you filed it in November.
MR. PRATT: November.
THE COURT: And then you just accepted numbers
without looking?
MR. PRATT: Well, you know, again, I have to say
that, you know, all I did was a guy says, “Here, you’ve
got to get this signed.” Or I think it’s probably my
attorney, “You’ve got to get this signed and out of
here.” So I signed it and off it went. I didn’t even
look at the million dollars until just recently, that Mr.
Green [respondent’s counsel], here, showed it to me and
pointed it out.
Petitioner further testified at trial that with respect to the
1995 return: “As far as I am concerned, he just wrote some numbers
down and my accountant probably--I mean my attorney at that time
probably said, ‘look, you haven’t filed that thing’; * * * he
probably went back to his office and made one, real quick”.
Petitioner contends that he simply provided the information to his
accountants and that the accountants decided the amount of
deductions to which petitioners were entitled. A cursory look at
the return would have revealed the large increase in gross receipts
reported on the return--gross receipts that petitioner testified
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011