William and Shirley Pratt - Page 22




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                    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            







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