- 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 testifiedPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011