- 19 -
At one point during petitioner’s testimony, the following
exchange occurred between the Court and petitioner:
THE COURT: All right. Now, let me ask another
question. You’re a lawyer with a license at risk. You
knew you had an obligation to file a return and that
that return had to be filed timely or you were going to
have a problem.
THE WITNESS: Right.
THE COURT: Why didn’t you protect yourself
better?
THE WITNESS: I suppose I’ve asked myself that a
million times. It –- I think part of –- when I think
back on it, I was very used to going ahead and doing
things, but, in this particular situation, [Rowe] had
paid in no money for the self-employment tax, and it
appeared that he was going to have a liability on his
side of the fence. And my push to get done and his
reluctance and his being the primary contact with Aunan
was not a good combination.
But, you know, all excuses aside, I have to be
responsible for myself. And I did not do in my own
mind, which is –- what I should have done is -- I did
not fire him. I did not report him. And I did not go
to my old accountant and file a separate return, no
matter what the economic consequences.
VIII. October 17, 2000, Order
After respondent filed his status report and supplemental
status report (SSR) describing the results of the parties’
posttrial efforts to resolve outstanding issues, we issued an
order dated October 17, 2000, which (1) listed the Schedule C
income and deduction amounts remaining in dispute after
respondent’s further concessions, (2) ruled upon various
exhibits, the admissibility of which had been left open at trial,
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