Brulé
J.T.C.C.:
—
What
concerns
me,
Mr.
Sarna,
is
this
that
what
happens
by
you’re
saying
there
was
a
partnership
which
we
don’t
have
evidence
of,
that’s
one
side
of
the
story,
and
I’m
prepared
just
to
ignore
that
for
the
moment,
but
what
really
troubles
me
is
that
you
in
your
tax
returns
signing
everything
to
be
true,
you
said
that
50
per
cent
of
the
situation
was
yours
and
50
per
cent
was
your
wife’s
because
your
brother-
in-law
was
out
of
the
country.
But
by
his
being
out
of
the
country
and
you’re
only
claiming
25
per
cent
for
you
and
your
wife
as
you
say
today,
it
means
that
50
per
cent
of
what
is
here
is
not
able
to
be
assessed.
We
don’t
know
where
he
is
so
he
escapes
any
tax
whatsoever
on
the
gains
because
he
wasn’t
here
and
you
assumed
his
position
and
you
signed
the
tax
returns
that
that
was
true.
And
as
far
as
I’m
concerned
you’re
stuck
with
that
position
because
there’s
no
way
that
the
Revenue
can
get
after
him
now
and
anything
that
took
place
in
this
period
would
be
statute
barred
anyway.
So
the
figures
in
the
return
I
accept
as
being
correct,
and
whether
they’re
correct
or
not,
you
put
them
in,
you
signed
they
were
correct
and
that
has
to
be
the
situation.
And
for
that
reason
your
appeals
are
dismissed.
Appeals
dismissed.
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