{
  "document_metadata": {
    "page_number": "13",
    "document_number": "A-5915",
    "date": null,
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  "full_text": "CAC3PARC\n1 tax returns.\n2 At the end of the day, the government's brief takes\n3 you at great pains through each of those three backdating\n4 transactions. And I should say, quote, backdating\n5 transactions. What you learn is what is undisputed is that's\n6 what happened. Mistakes in the craziness of this law firm\n7 where you were churning these things out every December and\n8 taking a portion of the losses into income, the tax loss, in\n9 the craziness of that and mistakes were made. And trades were\n10 done to try to correct the mistakes. You can't dispute that.\n11 The only question at the end of the day, as I say in\n12 the papers, is mens rea. And the mens rea when you read the\n13 government's evidence, the bottom line is he must have known.\n14 And he must have known because he was an accountant.\n15 And what we know on that is I think for two years, in\n16 the '80s, he was a junior accountant at 20 some thousand\n17 dollars a year. There is not a shred of evidence that he ever\n18 took a class that taught, quote, the annual accounting rule,\n19 and I think the Court knows the Second Circuit precedent that\n20 says \"must have known\" is an argument, but it's not of great\n21 weight.\n22 And I'll stop with this. I have to say, I wasn't in\n23 the must've known category. This wasn't something that I was\n24 taught in tax law. Maybe I forgot it and maybe the answer is\n25 it's so obvious you didn't have to teach it. But I said to\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00010170",
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      "type": "printed",
      "content": "CAC3PARC",
      "position": "header"
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      "type": "printed",
      "content": "1 tax returns.\n2 At the end of the day, the government's brief takes\n3 you at great pains through each of those three backdating\n4 transactions. And I should say, quote, backdating\n5 transactions. What you learn is what is undisputed is that's\n6 what happened. Mistakes in the craziness of this law firm\n7 where you were churning these things out every December and\n8 taking a portion of the losses into income, the tax loss, in\n9 the craziness of that and mistakes were made. And trades were\n10 done to try to correct the mistakes. You can't dispute that.\n11 The only question at the end of the day, as I say in\n12 the papers, is mens rea. And the mens rea when you read the\n13 government's evidence, the bottom line is he must have known.\n14 And he must have known because he was an accountant.\n15 And what we know on that is I think for two years, in\n16 the '80s, he was a junior accountant at 20 some thousand\n17 dollars a year. There is not a shred of evidence that he ever\n18 took a class that taught, quote, the annual accounting rule,\n19 and I think the Court knows the Second Circuit precedent that\n20 says \"must have known\" is an argument, but it's not of great\n21 weight.\n22 And I'll stop with this. I have to say, I wasn't in\n23 the must've known category. This wasn't something that I was\n24 taught in tax law. Maybe I forgot it and maybe the answer is\n25 it's so obvious you didn't have to teach it. But I said to",
      "position": "main"
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010170",
      "position": "footer"
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "'80s"
    ],
    "reference_numbers": [
      "A-5915",
      "DOJ-OGR-00010170"
    ]
  },
  "additional_notes": "The document appears to be a transcript of a court proceeding or testimony. The text is typed, and there are no visible stamps or handwritten annotations. The content discusses tax returns, accounting practices, and legal arguments related to a case."
}