This case is interesting because it was not a tax protester case but it applied Torres and other Fiscal Arbitrators decisions to find this investment banker grossly negligent for failing to report $18 million of taxable dividends in his 2007 tax return.
The banker blames his accountants for failing to include properly the $18 million in his tax return. The most damning fact was that the taxpayer had set aside $4.5 million in February 2007 in an investment account to mature April 2008 for payment of the taxes. Obviously, the investment would have matured, but the banker never pursued the related unreported tax liability with his accountants. For Bocock J., the key focus, though, was that the banker signed his tax return, uncharacteristically, without reading it or discussing it with his accountants.