- 15 - after the new year in January of 1997, I wanted to know where it was. I wanted to follow up with it. I--and because this was more money than I ever made in my entire life. So I wanted to try and find out where it was. Obviously, I didn’t do a good job. I missed things. But it was because of, that I was making a vast amount of money and I wanted to know where it was, Your Honor. And perhaps I should have started sooner, but that’s where I started right after the new year in January of 1997. Both of the joint returns in issue here were filed subsequent to the inquiries he described. Petitioner stated on brief that “he chose not to” handle the family’s financial affairs. This choice does not relieve petitioner of the duty to investigate blatant factual inconsistencies in the materials provided to him. Petitioner testified that he never requested original bank statements from Ms. Trevino or from the banks directly. Petitioner alleged in the petition that Ms. Trevino offered photocopied bank statements because, she said, the banks would not provide originals for accounts with such large balances. Petitioner was satisfied receiving photocopies of bank statements that were filled with obvious errors. All of the materials that petitioner presented at trial as evidence of Ms. Trevino’s alleged misrepresentation were highly suspect and would put a reasonable person on notice that further inquiry was needed.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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