AMERICAN PATRIOT NETWORK TAX FREEDOM NETWORK
Q And it shows various entries here for money; is that right?
A That's correct. The first line, 8, is taxable
interest, line 12 is alimony received, and then line 23 is
the total of those two items.
Q And then at, the bottom there is a total figure
down there of $23,000?
A Yes. Twenty-three thousand. That's the
adjusted gross income.
Q Now, is this the second page of the 1040?
A Yes, sir.
Q And you see that there is some calculations
here at the top part?
A That's correct
Q Then at the bottom there are two signatures?
A Yes. The signature, "Your signature" is Lloyd
R. Long, and "Spouse's signature," Dana Long.
Q Now, there were schedules attached to the
return, were there not?
A Yes, sir.
Q A Schedule C?
A Schedule C, yes.
Q It shows a Mr. Long as a contractor?
A That's correct. Schedule C is a Profit and
Loss from a Business.
Q And it shows gross receipts or sales?
A Yes, gross receipts or sales, $30,000.
Q And then there were certain expenses that were
taken off?
A That's correct. Travel, $5,514; meals and
entertainment, $1,800.
Q Now, attached to the return, do you find these
two documents?
A Yes, sir. Those documents are Form 1099. It
shows earning from savings and loan association, credit
union and bank deposits from AEDC Federal Credit Union,
showing that Mr. Long received $748.98. That's the lower
document on the large exhibit. The Form 1099 Miscellaneous
from Maury County Board of Education, which is the top
document on the large exhibit, shows nonemployee
compensation of $30,000.
Q Now, going back to the second page or the back
page of the 1040 again, at the very bottom there's a line
for preparer's signature?
A Yes.
Q Did anyone fill in that space, indicating that
someone other than Mr. Long and his wife had prepared this
return?
A No, sir. It's blank.
MR. COLLIER: Your Honor, we would offer these.
These are summary exhibits 10-A through G, I believe.
MR. BECRAFT: Your Honor, you know, I didn't
object to the underlying documents. Now we've got the
blowups. I don't have any objection to the use of the
Court, but my objection goes to, you know, if they want to
offer it into evidence for the purposes of carrying it back
into the jury room at a later point in time, I do have a
little problem with that. They're large. We've already got
the other exhibits in evidence. These are nothing more than
blowups of it. And I think to have charts like that back in
the jury room would be...
THE COURT: This is S-10?
MR. COLLIER: Yes, Your Honor.
THE COURT: All it is is blowups of Exhibit 10,
right?
MR. COLLIER: That's right, Your Honor. That's
what the witness testified to.
THE COURT: They're received.
(Government Exhibits S-10 A through G were
received into evidence.)
BY MR. COLLIER:
Q Now, were you asked to do a search to see if
you could locate the income tax return for the years 1989
and 1990?
A Yes, sir, I was.
Q And what did you find when you searched for
those income tax returns?
A In searching the permanent records for tax
years 1989 and 1990, I found that there were no returns
filed.
Q I'm going to show you Government Exhibits 13
and 14.
A Yes, sir.
Q What are those?
A Government s Exhibit No. 13 is a Certificate of
Lack of Record on which it appears to show I researched the
permanent record for a return for 1989 for Lloyd and Dana
Long. Government Exhibit 14 is a Certificate of Lack of
Record to show that I researched and found no return for
1990.
MR. COLLIER: Your Honor, we would offer those
two into evidence.
MR. BECRAFT: No objection.
THE COURT: Thirteen and 14 are received.
(Government Exhibits 13 and 14 were received
into evidence.)
Q Now, we've talked about the years 1986 through
1990. Did your records show whether Mr. Long had filed
returns prior to 1986?
A Yes. Our records show that he had filed
returns.
Q And when was the first time he had filed a
return?
A Pardon me?
Q Do the records show when he first filed a
return?
A Yes. The records indicated 1969 the first
return was filed.
Q Okay. Now, I'm going to show you, I'm going to
hold it up so the jury can't see it, but have you seen this
before?
A Yes, sir. I prepared that.
Q What is that?
It is a listing by year as to a return filed by
Lloyd Long from 1969 to 1990.
Q You prepared this yourself?
A Yes, I did.
Q And you base what is on this upon your own
efforts and your own searching?
A And my own search, yes, sir.
MR. COLLIER: We would offer this, Your Honor.
This is S-6, I believe.
MR. BECRAFT: Your Honor, my objection here on
this is the prosecution is using a lot of -- there's
obviously some other public record that forms the foundation
for this. It seems like the prosecution wants to use a
bunch of big blowups, I guess to take up space in the jury
room. There's got to be an underlying document for this.
The witness has said, "I searched the permanent record and I
pulled it out off the permanent record and made this chart."
I think the permanent record ought to be in evidence to
prove the accuracy of the chart. I mean, this is a chart
prepared for trial.
THE COURT: Well, do you have the -- where are
the underlying documents? Do we have the underdying
documents?
THE WITNESS: They're on master file tape.
THE COURT: Do you question the accuracy of the
information?
MR. BECRAFT: Well, Your Honor, I have one here
I'll be talking about with the witness with it. I glanced
at the chart, and I think the chart is probably an accurate
reflection of the underlying record that I have.
My objection is I don't think this is
inaccurate information that's on there, but the original
record from which it's pulled off -- the witness just
testified that she prepared the chart, she looked at some
other public record. I'd rather have the public record, the
actual public record into evidence rather than another
sizable chart.
MR. COLLIER: Mr. Becraft, of course, can offer
any record into evidence he wants to. He can subpoena it.
Mr. Leonard was shown this document, I would say, at least
two weeks ago. He had a chance to look at it. He told me
that it was accurate. They had no objection to it.
THE COURT: Well, under Rule 1006, with the
summaries, what we're talking about here, my understanding
is that one of the requirements is that the underlying
documents must be made available.
MR. COLLIER: And they were, Your Honor. I
told the defense about this record and where it came from,
and they had no problem with it.
THE COURT: In other words, what you're telling
me, you're making the representation to me that you have
made the underlying documents available to the defense?
MR. COLLIER: Yes, Your Honor.
MR. BECRAFT: Your Honor, my point is that
they're not offering that -- they want to keep offering
these huge charts, and I don't know whether they're going
back into the jury room or not.
THE COURT: Well, okay, let me just say this,
do we have any of the underlying documents available here?
MR. COLLIER: I can check and see, Your Honor.
(Brief pause.) We think we probably do, Your Honor.
THE COURT: Here's what we should do then. Go
ahead and let's, once you collect those let's offer those as
an exhibit, a separate exhibit. And then once we have
those, then we can, I'll admit the summary, with a special
instruction to the jury as I'm required to do with
summaries.
MR. COLLIER: It's Defense Exhibit 17, Your
Honor.
THE COURT: Defense Exhibit 17.
MR. COLLIER: Defense Exhibit 17.
THE COURT: That's the master file.
MR. COLLIER: We will offer at this time, not
for purposes of showing it to the jury, though, but solely
for purposes of establishing the underlying basis for the
chart. This is separate from the witness's testimony. But
this is an underlying basis. She testified that she looked
on the thing and she prepared this herself. This is almost
like an oral testimony.
THE COURT: Well, I understand that, but it's
based on information in the IRS.
Hand this document to Ms. Jeu.
Ms. Jeu, do you recognize this?
THE WITNESS: Yes.
THE COURT: What is it?
THE WITNESS: It's a hard copy of the permanent
record, the master file.
THE COURT: And the information that's on this
chart that Mr. Collier showed you, is that borne out by --
is what's on the chart borne out by what's on that master
file?
THE WITNESS: Yes, sir. It shows that he has a
period, 1969 through 1986, which is on retention register.
THE COURT: Well, what I'd like to do, if you
want the summary in, Mr. Collier, what we'll do is we'll
admit the master file and then we'll admit the summary.
MR. COLLIER: Okay.
THE COURT: Okay. So Defense 17 then is
received.
And ladies and gentlemen, this summary, what we
have here, which will be Government Exhibit S-6, and that's,
S-6 is received. And I should tell you that the summary
itself is not evidence, but it can be used by you in
evaluating the evidence in this case. The evidence itself
is the master file, which is Exhibit 17, Defense Exhibit 17,
which has just been. offered.
All right.
(Defense Exhibit 17 was recieved into
evidence.)
(Government Exhibit S-6 was received into
evidence.}
MR. COLLIER: We tender the witness, Your
Honor.
THE COURT: Cross-examination?
MR. BECRAFT: Before I proceed, Your Honor,
that last exhibit, I have one with the exhibit sticker on
it. I would like to substitute the one that has the sticker
on it for -- the witness can keep that copy.
THE COURT: Okay. As long as they're the
same --
MR. BECRAFT: They offered my exhibit.
CROSS EXAMINATION
BY MR. BECRAFT:
Q Ms. Jeu, you've testified that you've been with
the Internal Revenue Service for some 18 years; is that.
correct?
A It will be 18 years in November, yes, sir.
Q And you've been trained to do a particular job,
which is work with the criminal investigation branch at the
service center, right?
A For the past eight years, yes, sir.
Q That includes, when people like special agent,
our special agent here, want to find out something about
whether someone has filed some returns, they contact people
like you, correct?
A That's correct.
Q And then you've also come to testify. You
testify regularly in court in tax matters; is that correct?
A When subpoenaed, sir.
Q And you come to court for the purpose of
testifying, like you've done here, that somebody hasn't
filed a return or these are the returns that have been
filed; is that correct?
A I testify to present the information that's on
the permanent record.
Q Now, you've testified in a variety of cases
before, have you not?
A Yes, I have.
Q Do you have a judgment, you can tell the jury
about how often?
A I have no idea.
Q More than ten?
A Yes.
Q More than twenty?
A Yes.
Q So, a lot?
A In eight years, yes.
Q All right. And to come to court to testify,
you have to -- you've used this term "permanent record"
several times when Mr. Collier was asking you questions,
right?
A Yes, sir.
Q Now, that permanent record is Defense Exhibit
No. 17, correct?
A That's correct.
Q Now, in reference to -- let's take a look at
this particular chart here. That permanent record that you
have in front of you consisting of, I guess about four or
five pages, it says "IMFMCC transcript complete" up at the
top, right?
A That's correct.
Q Now, on that very first page you can see down
here, about the middle of the page it says, "Modules removed
to retention register"?
A Yes, sir.
Q And it's got 30 and then a set of numbers,
6912, right?
A Yes.
Q And so when you say that Lloyd Long first
started filing returns in 1969, the source for that
assertion of fact comes from this page, that 6912, right?
A Yes, sir. The source is here for 69.
Q So, on the very first page, you can go down
through here, it says '69, '70, '71, all the way up through
'86, and you can see that returns were filed for those
years, correct?
A No, sir, not by looking at this first page.
Q Well, why do you make that statement?
A I made this statement to say that '69 through
1986 has an account, there is activity; but from this page I
couldn't tell you what is there.
Q Well, but you've said on direct -- you produced
this chart right here to show that he filed from '69 to --
well, you've got all way up through '90, but starting out in
'69, and produced this chart. Did you consult some other
type of information?
A Sir, if you'll notice on Exhibit 17, it states
that the years '69 through '86 is on the retention register.
Q Did you consult that retention register?
A I did, sir.
Q So, that's where you got that information,
some other document?
A For '69 through '86, yes.
Q And because some other record showed that for
'69 through '86 that there was indicators of returns having
been filed, that causes this type of data to show up on the
face of page 1 of Exhibit 17, correct?
A No, sir, it did not cause it
Q Well, in any event, this is an accurate
depiction that for these years returns were filed; is that
correct?
A It's not an accurate picture that the return
was filed. I have to look at each individual module to find
out what's there, each individual year.
Q Now, let's take a look -- can I take you --
you've offered into evidence -- we don't have here on
Exhibit Number 17, besides this number at the bottom of the
page, this isn't a printout of the account that relates to
the year '86; is that correct?
A That's correct.
Q It starts off with '87?
A Yes, it does.
Q Now, let's ask some questions about '87. I
think Exhibit No. 11 is a photocopy of the '87 return; is
that correct?
A Yes, sir.
Q Now, up at the top of the page, in the upper
right-hand corner there's a set of 13 or 14 digits, correct?
A That's correct.
Q Now, the way you would locate that particular
return is you'd pull up this computer file?
A Permanent record.
Q The permanent. And then the first thing you
would do is you would look for some type of notation in the
computer record as to where you could find that particular
return; is that correct?
A The identifying number of the return, yes,
would be there.
Q So, you could look at -- can I get you to take
a look at the field of information that applies to 1987?
A Yes, sir.
Q Now, down there at the bottom of the page
there's 6010; is that correct?
A Yes, it is.
Q The way the service center keeps up with
information that flows into it, you put numbers on the
documents, right?
A Correct.
Q And then you take the information off the
documents and load it into the computer, right?
MR. COLLIER: Your Honor, I'm going to object.
This is beyond the scope of direct examination, first.
Secondly, the document has already been admitted into
evidence. So, I'm not sure what the purpose of this entire
line of questioning is. If he wanted to object to the
documents, he could have and could've cross-examined the
witness before they were admitted. The documents are in
evidence now.
MR. BECRAFT: Well, Your Honor, the
Government's offered documents and I think I'm entitled to
cross-examine them on it. That's all this is.
THE COURT: Well, overruled. Let's move on,
though.
BY MR. BECRAFT:
Q Now, the way you find the return is you look at
computer records, see a number down there, and then you ask
the people over at the records center to pull it up, right?
Right.
Q Now, even though we don't have a field of
information here for '86, you looked at '86, saw the numbers
that appeared on a computer printout, and you asked the
records center to find the documents bearing those numbers,
right?
That's correct.
Q And they sent them to you?
A Yes.
Q They produced '86, '87 and '88 because that's
what you wanted, right?
A They produced '87, '88.
Q I think 12 is '86?
A Yes, '86, '87 and '88, yes, sir.
Q Now, what you did for the years we're dealing
with here, '89 through '90, what you did to determine that
there hadn't been a return filed is you looked at this
particular record, correct?
A That's correct.
Q Now, this is just, this is one that's printed
out on August the 13th of '93, correct?
A Yes, sir.
Q Now, the documents, the certificates of lack of
record, Exhibits No. 13 and 14, are dated what?
A September 22, 1993.
Q So, you would've gotten probably a printout,
the underlying computer record -- those two documents that
you have in your hand here, the Certificate of Lack of
Record, are made by looking at this type of a document known
as the permanent record, Exhibit No. 17, right?
A Yes, that plus I check further for a return
that was filed under another SSN or something of this nature
which would've been under his name. But I checked to see if
there was any return under his name or under any number.
There was nothing.
Q Okay. Now, there are two types of transcripts,
is that correct, a complete and specific?
A No, sir. There's more than that.
Q Well, at least those two, correct?
A Yes.
Q Now, did you bring with you to court these
types of documents that were used to prepare Exhibits No. 13
and 142
A Not to the courtroom, no, sir.
Q Have you got them in the U.S. Attorney's
office?
A Yes, sir.
Q In your purse?
A No, sir.
Q Or briefcase rather. In your possession?
A Yes.
Q And if we pulled those out, they would look
like Exhibit No. 17, except maybe with a later date?
A A later date.
Q Now, when the jury takes a look at this
document here, we're talking about a lot of symbols, codes;
is that correct?
A Yes. It's the permanent record.
Q And you have to -- you're someone that's
familiar with the meaning of all these codes; is that
correct?
Yes, the ones I have to use.
Q Now, the ones you have to use, you had to use
one of these symbols of 150, right? You're familiar with
transaction --
For the benefit of the jury, a 150 means a
return is posted for that year.
Q So, for '86, '87 and '88 you found a 150
appearing on the computer transcript, right?
A Yes. He filed a return for those years.
Q And then you were able to, with the information
on the computer record, pull those up. So, you knew he had
filed returns, right?
A Yes.
Q Now, we're talking about an absence of records
for '89 and '90, correct?
A No. There are records for '89 and '90, but
there's no return for '89 and '90.
Q That's the point I meant. And do you draw this
conclusion that no returns were filed because there isn't a
computer symbol of a 150? Is that right?
A That's correct. That's the only thing that
would indicate a return filed.
Q Okay. So, it's the absence of a computer
symbol that would indicate the return was not filed. And
then from that conclusion you draft the document, Exhibit
No. 13 and 14, right?
A I know by looking at the tax years '89 and '90
that there is no tax return filed.
Q Through that process I've just described,
right?
A Through the process of me checking the
permanent record for any returns filed by Mr. Long.
Q Now, can I get you to take a look at the very
front page of Exhibit No. 17?
A Yes, sir.
Q Let's be very specific. You're familiar with
the meaning of symbols that appear on here?
A What symbol?
Q well, specifically do you see a symbol called
MFR1?
A Yea, I do.
Q And it takes a book to understand the meaning
of that term; is that correct?
A We have many handbooks, sir.
Q And one of those handbooks is called Integrated
Data Retrieval document, known as Document Number 6209,
right?
A Well, that's not a handbook. That's a
document.
Q Okay. But it's a document that -- you've seen
the document before yourself, right?
A Yes, sir.
Q And you read and rely upon the document,
correct?
A No, sir.
Q Well, it contains the descriptions or meanings
of some of the symbols appearing on the permanent record,
right.?
A Some of them.
Q Okay. It does have MFR1; is that correct?
A Pardon me?
Q It does have the meaning of MFR01, right?
A Yes, it does.
MR. BECRAFT: May I approach the witness, Your
Honor?
THE COURT: No. You can hand it to the clerk.
MR. BECRAFT: I'm sorry, Your Honor. I will.
Q Now, Ms. Jeu, can I get you to thumb through
the document right there and see if you recognize that as
the decoding manual, document 6209?
MR. COLLIER: Your Honor, again I'm going to
object.
THE COURT: Yeah. Where are we going with
this, Mr. Becraft?
MR. BECRAFT: If the Court wants a side bar, I
think --
THE COURT: Yes, I do. Let's go to side bar.
(Side bar conference was held outside the
hearing of the jury, as follows:)
MR. BECRAFT: I've had her before, Your Honor.
But this symbol right here is the one I'm talking about,
MFR01. She's told me this stuff before. But the manual she
has -- this is a separate manual that's related to this.
The meaning for the symbol here on the defendant's permanent
record, the symbol is "Return not required to be mailed or
filed.
MR. COLLIER. This is beyond the scope of
direct examination.
THE COURT: Are you contending that he filed a
return?
MR. BECRAFT: No, no, Your Honor. They've
admitted that this is the underlying computer record, the
permanent record. And when you decode it, there's an
admission here. And there's a couple of cases in the
shorter trial brief, Your Honor, that I can consider this an
admission, a party admission. She knows these. I've had
her before. She's identified them, as they all do. They've
identified this. I've got a transcript. It's admission --
THE COURT: Admission of what?
MR. BECRAFT: There are two cases that I talk
about, one is Van Griffin and the other one I can't
remember. But it's an admission, party admission, Your
Honor, what this code means here.
THE COURT: An admission by what party?
MR. BECRAFT: The IRS.
THE COURT: An admission about what?
MR. BECRAFT: That they've got a code on here
that's says return not required to be filed. That's
exculpatory. The government is saying he's required to
file, but the computer says --
MR. COLLIER: Did he rely on that?
MR. BECRAPT: No.
MR. COLLIER: Then how can it be exculpatory if
he didn't rely on it? What you're talking about is the law.
Only the Court can tell the jury what the law is.
THE COURT: Is it your contention he was not
required to file a return?
MR. BECRAFT: No, I'm not saying that. I'm
just saying I find it extremely interesting to represent to
these people -- and now that I've learned how to decode
these things, their people come along and they tell me,
yeah, this means this and this means this, they identify
this document, and then they tell me the computer says
return not required to be filed.
Now, whether or not he relied on it is
irrelevant. Most exculpatory evidence is not something that
somebody relied upon. It's the documents that come out of
the government's possession. This one came out of the
government's possession.
THE COURT: I'll tell you what, I find this
whole thing to be a whole lot of doublespeak. However, I'll
let you ask a few questions about it and then let's move on.
MR. BECRAFT: I will do that, Your Honor.
(Side bar conference concluded and proceedings
continued in open court, as follows:)
THE COURT: We need to take a recess for about
ten minutes.
(Brief recess.)
(Proceedings were held outside the presence of
the jury, as follows:)
THE COURT: We have a slight problem in that
Mr. Foster just got word that his father-in-law is very ill
and not expected to live, and so I have excused him. He was
Number 12. So, we will substitute the first alternate, Ms.
Clark, 118. We'll do that when we come back in. That's why
we have alternates. All right. So, call the jury back.
(Jury returned to courtroom and proceedings
continued in their presence, as follows:)
THE COURT: All right. You may proceed.
BY MR. BECRAFT:
Q Ms. Jeu, right before our break we were
discussing certain symbols on Exhibit No. 17, the permanent
record?
A Yes.
Q Do you have that in front of you?
A Yes, sir.
Q Now, I handed to you a book a moment ago and
asked for you to identify the book for us, please. Did you
do so?
A No, sir.
Q You didn't?
A No, I did not say anything of what it was.
Q No, I'm sorry. I didn't mean to -- do you
recall that that is a copy of document 6209?
A Yes.
Q Okay. And that's an accurate copy of it,
right?
A A what?
Q That is an accurate copy of the manual that you
use?
A I could not verify that, sir.
MR. BECRAFT: Your Honor, I'm going to object
to that question.
THE COURT: Well, overruled.
A (Continuing.) That's the manual that I use,
sir.
Q But there's one for every year. If we had them
here, they'd have colors on them that say '87, '88, '89,
'90. They're little pamphlet type books about this size,
right?
A Yes, it's that size, but it's not the book that
I use.
Q Okay. But you're familiar with it, right?
A I'm familiar with it, yes.
Q What book do you use?
A I use the normal procedure handbooks for the
Internal Revenue Service.
Q Is that --
A Which there are many.
0 Is one of them a law enforcement manual?
A Yes.
Q Would it be this document right here?
A (Reviewing document.) Yes, this is one of the
IRS manuals that's used.
Q Now, regrettably I had my finger on the page,
but I think it's Section 4.2, the one I just handed to you.
Have you found it?
A 4.2, yes, sir.
Q Okay. Is there a section in there that deals
with 1040s?
A Yes.
Q Okay.
Could the witness be handed this?
On Exhibit No. 17, can I get you to, for the
benefit of the jury -- I've handed you a yellow highlighter.
Could you highlight on that exhibit the MFR that we're
talking about?
A The MFR that you're talking about is not on
exhibit -- this book that you've given me on 4.2.
Q I'm sorry. Referring back to Exhibit No. 17,
on the very front page. I've asked you a question about the
symbol MFR01.
A Okay.
Q Now, can you just line through that symbol?
A (Witness complies.)
Q Have you done so?
A Yes, sir.
Q Now, speaking about the meaning of that
particular symbol, have you found the place in that
particular manual that provides the meaning for that?
A No, sir.
MR. BECRAFT: Your Honor, I could find it.
MR. COLLIER: Your Honor, I would object to
this. The witness testified that she did not rely upon this
document. Her response in regard to this document was this
is one of the things that they use. Now he's trying to get
her to, I'm not sure what. But he is way far afield.
THE COURT: This document you've got there, did
you rely on that at all in determining whether or not a
return was filed?
THE WITNESS: No, sir.
THE COURT: Okay.
MR. COLLIER: Withdrawn.
BY MR. BECRAFT:
Q However, that is a document that you use to
provide meanings to the symbols that appear upon the
document that you do rely upon, correct? Let me withdraw
this. You have relied upon Exhibit No. 17, the permanent
record, correct?
A Yes, I have.
Q And to prepare the documents you offered into
evidence, you looked at a document like Exhibit No. 17 and
you drew conclusions from it, right?
A Yes.
Q And the manual that you have in your hands
right now, one of those law enforcement manuals, provides
the meanings to all this computer jargon that is not printed
in plain English on the document, right?
A No, sir, it does not. It does not, this one
book does not tell you what everything is on this.
THE COURT: Does it say anything on there?
THE WITNESS: It tells you transaction codes
which is on the individual year, which would be, like a 150
would symbolize a return, a 610 symbolizes a check, money
received.
MR. BECRAFT: Your Honor, it'd be quicker if I
found the page.
THE COURT: Okay. Come on up here. Find the
page. Let's go.
MR. COLLIER: Your Honor, before anything is
read out of the book, I'd like to have the witness, if she
can do it, and if she can't do it, someone else,
authenticate that particular document. So far we have no
assurance that is a true and accurate copy of anything that
the Internal Revenue Service ever published.
THE COURT: Let's find out what the question
is.
BY MR. BECRAFT:
Q Ms. Jeu, keep your finger on the page that I
have. Okay. Now, you're familiar with the symbol that I
brought to you attention, is what we call a mail filing
requirement, right?
A That's correct.
Q So, you're familiar with that?
A Yes, I am. It tells us what type of return
that the taxpayer filed in the year prior so that we can
mail a package out to him the following year, a 1040A or
1040, did you use Schedule C. Or if you had individual
income, profit and loss there, you'd get a Schedule C. But
if you filed a 1040A, you would get a return with just the
1040A in it.
Q Now, the meaning, there's a section that
provides the meanings for the mail filing requirements. And
that's, I believe, Section 4.2 in the very manual that you
have in front of you, correct?
A Right.
Q So, we're in that section?
A Yes, we are.
Q Now, flip down to -- does it list forms there
and have numbers below it?
A Yes, it does.
Q Now, are you at 1040?
A Yes.
Q Okay. Now, we're dealing with MFR01, correct?
A That's correct.
Q And that book provides the meaning of MFR01,
correct?
A Yes.
Q And the meaning is?
A The file requirement for 01 is return not
required to be mailed or filed.
Q Now, that's the official definition of a symbol
that appears on Lloyd Long's permanent record?
A To date, yes.
Q Correct. Now, this particular field, this
computer data appears at the very top of the front page on
Exhibit No. 17, and then down below it you start off with a
year, a field of information?
A Yes.
Q All right. Now, down here at the bottom it
says tax period 30-87-12. That means for the year 1987,
right?
A Yes. Tax period 30 means Form 1040. That 30
indicates 1040. And 87-12 means the year '87, ending month,
year, December.
Q Now, while this stops at the bottom of the page
and begins the information, it happens to be down at the
bottom of the page, the '87 information, it goes over onto
the second page, right?
A Yes.
Q And then after that, the field of information
that relates to '87 stops and then we pick up with '88,
right?
A Yes.
Q And then we have a field of information on the
third page that relates to '88, right?
A Yes.
Q And then after that we have at the bottom page
that, we have tax period 30-89-12, one of the years that
we're dealing with, right?
A Yes.
Q And then on the following page there's a bunch
of computer transactions that relate to that year, right?
A Yes.
Q All right. And then after that we have '90.
We also have '91 and '92, correct?
A Yes.
Q And the same document. And this computer
symbol, MFR01, applies to everything that's in this
document, correct?
A That applies to the entity module, the name and
address of this account, yes.
MR. BECRAFT: Nothing further, your Honor.
THE COURT: Any redirect?
REDIRECT EXAMINATION
BY MR. COLLIER:
Q Ms. Jeu, had you ever seen this particular book
Mr. Becraft gave you this morning? Had you ever seen that
book before, that particular book? Not another copy or
another version of it.
A I have not seen this book before, sir. I
have --
Q Do you know if anything or everything in that
book is accurate and true?
A No, I don't.
Q Until you took the stand this morning, Mr.
Becraft had never showed it to you?
A No, sir.
Q Now, Mr. Becraft asked you some questions about
a code. And I think he said that, according to his book,
that code may mean that there was not a requirement to file
taxes. You don't mean to tell the jury that Mr. Long is not
required to file taxes, do you?
MR. BECRAFT: Your Honor, object to leading.
THE COURT: Overruled.
A Repeat the question.
THE COURT: Repeat the question.
Q Your responses to Mr. Becraft's questions did
not mean to leave the jury with the impression that Mr. Long
was not required to file his taxes, was it?
A No, sir. The mail file requirement is changed
by certain transaction codes or the return that you file.
One year you may file a Form 1040A, but the next year you're
required to file a Form 1040, then our mail file requirement
would change.
In the tax year 1989, there are transactions
codes. These codes that we refer to as, like the 150 for
the return, is in this account. There is a transaction coda
there that changed the mail file requirement to 01, which
just, it's for -- I really don't know why. That's from
programming. But it was programmed to change the mail file
requirement. It does not mean that he is not liable for a
tax return. Your income would determine whether you're
liable for a return.
THE COURT: Okay. Anything else?
MR. BECRAFT: Briefly, Your Honor.
RECROSS EXAMINATION
BY MR. BECRAFT:
Q Are you telling this jury then that you don't
know what the computer -- let me withdraw that. Mr. Lonq
doesn't have access to IRS computers. He can't load
information into it, can he?
A No.
Q Everything, all these symbols that show up on
the permanent record, it's all in computer language?
A It's for the use within the IRS.
Q And you have to -- the only people that load
that type of data into the permanent record are IRS people,
right, people that work at the service center, like you?
A Employees of the Internal Revenue Service.
Q And so somebody inside the IRS has entered
something into the computer that causes the computer to
print out this symbol; is that correct?
A Yes.
Q And in this situation you have no explanation
as to why?
A No.
Q You don't know when this happened?
A When his account was referred from collection
to examination, a transaction, this is a reaction from a
transaction code that was input to refer his account to
examination.
Q But you don't know when it happened?
A No, sir.
Q It just appears there? The computer says so?
A It appears after it's been input, yes.
Q But it has been input and the computer prints
out this symbol?
A Yes.
Q And you don't know the reason why?
A No.
MR. BECRAFT: Nothing further, Your Honor.
THE COURT: Anything else from this witness?
MR. BECRAFT: No, Your Honor.
THE COURT: You may step down, ma'am. You're
free to leave.
(Witness excused.)
MR. COLLIER: Call Mike Geasley.
MICHAEL DEAN GEASLEY,
called as a witness at the instance of the Government,
having been first duly sworn, was examined and testified as
follows:
DIRECT EXAMINATION
BY MR. COLLIER:
Q Please state your name for the record.
A Michael Dean Geasley.
Q And how are you employed?
A I'm a special agent with the Internal Revenue
Service.
Q And what position do you hold with the Internal
Revenue Service?
A I'm a special agent.
Q I'd like to direct your attention back to July
of last year, of 1992. Did you have an occasion to speak to
the defendant in this case, Mr. Lloyd R. Long?
A I did, sir.
Q And did you have a conversation with him
regardinq his filing tax returns?
A I did, sir.
Q And did he tell you about when he first started
filing tax returns?
A He did.
Q And what did he say?
A He said approximately 1969
Q Did he tell you when he stopped his filing
income tax returns?
A He did, sir. He said 1988.
MR. COLLIER: We tender the witness, Your
Honor.
CROSS EXAMINATION
BY MR. BECRAFT:
Q That was so short, Mr. Geasley, I didn't catch
the last statement. You say he stopped when?
A In 1988.
Q Okay. Now, was there a reason why you had a
conversation with him in July of '92?
A Yes.
Q About the investigation of this case?
A Yes, sir, that's correct.
Q So, you asked for a meeting with him?
A No, sir.
Q Did he ask for a meeting with you?
A He did.
Q So, before this conversation you had been
issuing summonses, right?
A It's possible.
Q Okay. well, is that your recollection?
A I believe I did. I don't know the time on
that.
Q When you do that, you send a copy to people
like Lloyd Long?
A In certain cases third-party --
Q So, somehow, some way that we don't recall
right now, he knew that you were investigating him by July
of '92?
A I'd gone out to his house and interviewed him
on January -- excuse me, February 5th of '92.
Q Oh, okay. That's how you knew of it?
A Yes, sir.
Q Now, on this particular occasion did he
initiate the conversation or set up the meeting with you?
A I'm sorry, in which...
Q I'm sorry. I'm confusing. Who requested this
July 1992 meeting?
A Mr. Long did.
Q Okay. And where was the meeting?
A It was held at the Federal Building in
Winchester, Tennessee.
Q And the two of you showed up at the designated
time and designated place, had a conversation for how long?
A Probably about an hour. And it was more than
just the two of us.
Q And did he seem to be, in this conversation,
hiding anything from you?
A No, sir.
Q And he told you his position, his beliefs?
A To a certain degree.
Q He didn't hide the fact from you that he
started filing in '69?
A No, sir.
Q And that's accurate, right?
A I believe it is.
Q And he didn't hide from you the fact that he
stopped filing in 1988, did he?
A No, sir.
Q I mean, he freely admitted it?
A We had already had a conversation, yes.
Q Oh, okay. So, he had already previously
mentioned the same thing to you on prior occasions?
A No, sir.
Q So, this was the first time he told you he
hadn't filed since '88?
A Yes, sir, that's correct.
Q And isn't it true that for the year 1989 when
you started investigating this case, you saw that Mr. Long
had freely sent to the IRS copies of his 1099s for the year
1989?
MR. COLLIER: Your Honor, I object to that.
That's beyond the scope of direct examination. If he wants
to make this witness his own, he can in his own case.
MR. BECRAFT: I'll withdraw it, Your Honor.
There's no point. It'll be covered on our case.
THE COURT: Okay.
BY MR. BECRAFT:
Q Now, did he discuss with you certain reasons
why he didn't file?
A I believe he did.
Q Did you get the impression that he had anything
to hide?
A No, sir.
MR. BECRAFT: Nothing further, Your Honor.
THE COURT: Okay. You can step down, Mr.
Geasley.
(Witness excused.)
THE COURT: Next witness.
MR. COLLIER: Call Virginia Sherard
VIRGINIA SHERARD,
called as a witness at the instance of the Government,
having been first duly sworn, was examined and testified as
follows:
DIRECT EXAMINATION
BY MR. COLLIER:
Q Please state your name for the record.
A Virginia Sherard. S-h-e-r-a-r-d.
Q And in what city and state do you reside?
A I live in Rocky Face, Georgia.
Q And are you employed at this time?
A Yes. I'm an Internal Revenue agent.
Q And would you explain to the members of the
jury what your duties are as an Internal Revenue agent?
A I examine individual, corporate and partnership
returns to determine the correct tax liability.
Q And how long have you been so employed?
A I've been a revenue agent for about three
years.
Q And could you give the members of the jury some
idea of your educational background that you achieved before
you were employed by the Internal Revenue Service?
A I have a bachelor's degree in economics from
the College of William and Mary.
Q Now, once you were employed by the Internal
Revenue Service, did you receive any training to assist you
in your duties?
A Yes, I did. I started out as a tax auditor. I
was a tax auditor for eleven years. During the course of my
employment with Internal Revenue Service, I've received
diversity facility training, I've had advanced corporation
training, I've had expert witness training, quality process
improvement training.
Q Now, during the course of your employment with
the Internal Revenue Service, have you been required to
learn what the filing requirements are for various
individuals?
A Yes, I have.
Q Why is that? Why do you need to know that?
A We need to know what the filing requirements
are in order to determine, number one, whether we should
request a tax return from someone who has not filed. Also,
when we publicize during filing season, we need to be able
to tell people who needs to worry about filing a tax return
and who doesn't.
Q Do the filing requirements change from year to
year?
A Yes, they do.
Q Now, have you prepared some charts to assist
the jury with your testimony regarding the filing
requirements for 1989 and 1990?
A Yes, I have.
Q I'd like to show those to you. They're Exhibit
S-7.
MR. COLLIER: Your Honor, can she leave the
witness stand?
THE COURT: Sure.
Q The Exhibit S-7, using this exhibit would you
explain to the jury what the filing requirements were for
1989 and 1990?
A In 1989, the filing requirements for a person
filing a joint income tax return was $9,200. The reason it
was $9,200 is because it's made up of two things. It's made
up of what's called the standard deduction for a person
filing a joint return which was $5 200 in that year. And
it's made up of two exemption amounts: one for the husband,
one for the spouse. Both of those were $2,000. So, $5,200
plus $2,000 plus $2,000 is $9,200.
So, if you're filing a joint return for that
year, if you made under $9,200 you were not required to file
a tax return unless you wished to receive a refund of your
income tax withholdings.
For 1990, the filing requirement was $9,550.
Again, that was made up of two things: the standard
deduction for that year, which was $5,450. You can tell it
went up that year. And two exemption amounts. The
exemptions that year were $2,050. So, $5,450 plus $2,050
plus $2,050 is $9,550.
I'd like to point out to you that this is for
married people and filing a joint return. There were also
other filing requirements that were lower. In other words,
if you made even lower income you wouldn't have to file.
This is the most generous filing requirement.
If you were a single person, the filing
requirement was only $5,100, and if you were a head of
household it was $6,450, in 1969. So, this chart shows you
the most beneficial filing status and filing requirements.
Q Now, I believe that you have sat throughout
this trial, have you not?
A Yes, sir.
Q And you've heard the evidence in this case?
A Yes, sir.
Q I'm going to show you what's been marked as
S-8. What is that?
A This is a summary of Lloyd R. Long's gross
income from 1989. If you'll notice Maury County, we
received a great deal of testimony and also documents
admitted into evidence which show that as an instructor at
the Saturn plant there was $47,750 in contract labor income.
You heard testimony, Grower's Chemical Corporation, also
received documents, that showed commissions for being a
sales representative in 1989 was $742.50. You also heard
testimony and received documents that show from AEDC Federal
Credit Union there was interest income of $810.91.
The total gross income was $49,303.41. And if
you'll notice, compare it to the other exhibit, this is more
than five times the required filing amount.
Q Now I'll show you S-9.
A For 1990, you heard testimony and also received
documents and evidence, from Maury County, being an
instructor at the Saturn plant, contract labor income was
$48,675, and interest income from AEDC federal Credit Union
of $843.02, means total gross income is S49,518.02. Again,
this is more than five times the filing requirement for
1990.
Q Ms. Sherard, based upon your training and
experience and your knowledge, and also the evidence that
you've just testified to in these charts, can you tell us
whether Mr. Long was required to file an income tax return
for 1989?
A Mr. Long was required to file an income tax
return for 1989.
Q And can you tell us whether Mr. Long was
required to file an income tax return for 1990?
He was required to file for 1990.
MR. COLLIER: We tender the witness, Your
Honor. We would offer those exhibits into evidence that
this witness testified to, S-7, S-8 and S-9.
MR. BECRAFT: No objection.
THE COURT: All right. Ladies and gentlemen of
the jury, S-7, S-B and S-9 are received. I should mention
to you at this time that these are summaries. Summaries
themselves are not evidence, but are to be used, can be used
by you, if you wish, in evaluating the evidence.
(Government Exhibits S-7, S-8, and S-9 were
received into evidence.)
CROSS EXAMINATION
BY MR. BECRAFT:
Q Ms. Sherard, you don't know Lloyd Long, do you?
A No, I do not.
Q So, before today, Lloyd Long was just a name.
And if we hadn't already identified him for you as this
gray-haired fellow over here, you wouldn't even know who he
was, right?
A Yes, sir.
Q Never even talked to him, right?
A Yes, sir.
Q You've been brought in to testify and summarize
the evidence that's been offered, correct?
A Yes, sir.
Q You testified on direct that you've been --
well, let me back up. Did you say that you had a bachelor's
in economics from...
A College of William and Mary.
Q And when did you graduate?
A 1979.
Q That was in economics?
A Yes, sir.
Q And I take it sometime after 1979 or within a
month or two you went to work for the IRS?
A Yes, sir.
Q Did you work with the IRS before you got out of
school?
A No, sir.
Q So, the first time you started was then?
A Yes, sir.
Q So, you've been with them some 14 years?
A Yes, sir.
Q Have you always been stationed in Georgia?
A I spent a year in Atlanta and I've been in
Chattanooga since 1980.
Q So, you work here?
A I work in the Chattanooga office.
Q Now, in school did you have any particular
training in tax law?
A No, sir.
Q Did you take accounting courses?
A I did take accounting courses.
Q So, when you say you had a bachelor's degree in
economics, part of those courses, I don't care how many, but
you at least covered a lot of -- well, you had basic
accounting and you know how to engage in accounting work?
A Yes, sir.
Q And accounting is something that you need in
order to do your work for the IRS, right?
A Yes, sir.
Q And those accounting principles that you've
learned are used by you because you examine returns on a
regular basis; is that correct?
A Business returns, yes, sir.
Q Okay. How about individuals?
A Accounting skills are not as necessary for
individual returns. In fact, the requirement for being a
tax auditor who examines only individual returns is only two
semesters of accounting.
Q Okay. So, when we're talking about the
accounting that applies for an individual, it's real basic?
A Very basic.
Q If you can add and subtract and deal with
figures, you can do it, right?
A Hopefully.
Q Now, what training have you had -- I think
you've testified that, you know, it's your conclusion that
Mr. Long is required to file for these two years. Have you
studied the Internal Revenue Code?
A Yes, sir.
Q And since you didn't study it in school, then I
take it at some stage of your work for the Internal Revenue
Service you picked up training in this area; is that
correct?
A Yes, sir.
Q Can you describe for the jury how thorough that
training is, how often you have training, what type of
classes you've taken?
A When I came on as a tax auditor I received six
weeks basic tax auditor training. We have refresher courses
similar to the types of courses that we offer during our
volunteer income tax assistance, free to the public. As a
revenue agent I received six weeks of intensive training in
corporate and partnership law.
Q Can you give the jury just a rough ballpark
figure how, over the last 14 years how many classes you've
attended, a quesstimate?
A IRS classes?
Q Yeah.
A Probably about one a year.
Q And these would be for, the first one was six
weeks?
A (Moving head up and down.)
Q And how long would, approximately, the rest of
them be?
A The revenue agent class was about six weeks and
the refresher classes are several days each year.
Q So, total classroom time in 14 years would
amount to maybe tour or five months of studying?
A That sounds good.
Q And that includes course materials that the IRS
prepares, right?
A Yes, sir.
Q Study of the code?
A Yes, sir.
Q Study of the tax regulations, right?
A Yes, sir.
Q So, you've acquired through your training with
the IRS an expertise in this field?
A Yes, sir.
Q And you have to have this expertise to do what
you do, which is examination of business returns?
A Yes, sir.
Q Which are a lot more complicated than an
individual?
A Generally so.
Q And here in this case, what we're talking about
here with these charts and everything else, that's real
basic, right?
A Yes, sir.
Q Now, you've sat through this case and it's been
real quick. We haven't had a whole lot of items of income.
You've produced these charts, and you've taken those figures
from basically the 1099s that have been offered into
evidence, right?
A I believe there were also checks and ledgers
offered into evidence.
Q Well, the checks, you know, add up to what the
1099 is. You don't have any doubt about that, right?
A No, sir.
Q Okay. And so you used the 1099s as the items
that were providing the broad base figures, when you added
them up?
A To come up with the gross income figure, yes.
Q And for '89, you said the filing requirement
was $9,200, right?
A Yes, sir.
Q And for '90 it was what?
A $9,505.
Q $9,505. Now, that is, those two figures,
according to what you said on these charts, we're dealing in
a ballpark figure for both these years, forty-nine thousand
plus, right?
A Yes, sir.
Q And let's call it nine thousand as the filing
requirement. Right?
A Yes, sir.
Q And so, how much he made exceeded the filing
requirement, so you've reached this conclusion that he was
required to file a return, right?
A Yes, sir.
Q Now, that opinion of yours, that's based upon a
study of the Internal Revenue Code; is that correct?
A Yes, it is.
Q And I don't want to know the substance of it,
but can you at least inform us, can you give us a number in
the code that would deal with this subject matter, of
filing?
A I can.
Q Just give us the number.
A Code 6012.
Q Now, that's the one that directly relates to
the filing requirement, right?
A Yes, sir.
Q Now, it doesn't say, if we pull it out right
now here, it wouldn't say the nine-thousand-dollar figures,
right?
A No, sir.
Q Okay. Those nine thousand figures come from
some other place; is that correct?
A It comes from reading the entire text of Code
Section 6012A.
Q It depends upon what?
A I believe the code section states that any
individual shall file an income tax return if his gross
income exceeds his exemption amount.
Q Now, so we'd have to refer to other parts of
the code?
A Yes, sir.
Q To determine what those exemption amounts are,
right?
A Yes, sir.
Q Off the top of your head do you know what they
are?
A The exemptions are at 151, Code Section 151.
Q So, to determine this you'd have to -- would
151 say these figures?
A I believe so.
Q Okay. And they're probably changed every year?
A Generally.
Q Does Congress do that, to your understanding?
A To my understanding, yes, sir.
Q So, it's your understanding --you're not trying
to tell the jury that, you know, that section -- that your
opinion is based on Section 6012, right?
A I am saying that my opinion is based on Code
Section 6012.
Q And that requires you to look at another
section of the code, Section 151?
A (Moving head up and down.)
Q And once someone has done that, they would
learn the filing requirements?
A You cut me off a little bit on Code Section
6012A. It states that a person shall file an income tax
return if their gross income exceeds the exemption amount.
Then it lists certain exceptions. And the exceptions are
for married filing jointly, other filing statuses, and the
standard deduction amount.
Q We're not dealing with an exception here,
right?
A Right.
Q We're just dealing with the general rule,
right?
A (Movinq head up and down.)
Q Are these the only two that, the laws that your
opinion is based upon?
A I'm sorry?
Q I don't mean to say laws. That's a slip of my
tongue. We're talking about your opinion about the law.
A I'm not sure what your -- could you restate
that?
Q Yes, I surely will. My question to you, I
didn't mean to invade the province of the Court by talking
about laws. We're talking about your opinions. But these
are the only two laws that relate to this obligation to file
a return, right? In your opinion?
A Code Section 6012, the exemption section and
then the section that would state the standard deduction
amount.
Q Which is 151?
A The exemption amount is 151. The standard
deduction amount code section slips my mind for the moment.
Q Well, whatever it was.
A Whatever it was.
MR. BECRAFT: All right. Nothing further, Your
Honor.
THE COURT: Anything else?
MR. COLLIER: No redirect, Your Honor. the
Government rests.
THE COURT: You may step down. You're free to
leave.
(Witness excused.)
MR. BECRAFT: Just as a matter of record, I
realize that at this stage of the trial, at the conclusion
of the Government's proof there would be time for me to file
a Rule 29. However, based upon the proof that's come in
thus far, I don't have that argument yet, and it will depend
upon -- I will have a Rule 29 after the defendant testifies.
THE COURT: Okay.
MR. BECRAFT: Is the Court ready to proceed?
THE COURT: Ready to proceed.
MR. BECRAFT: Defense calls Lloyd Long.
THE CLERK: Do you solemnly swear the testimony
you're about to give is the truth, the whole truth, and
nothing but the truth, so help you God?
MR. LONG: Your Honor, I'm not certain that I
know the whole truth and nothing but the truth, but it is my
solemn intent to tell the truth as I know it from my
perspective.
THE COURT: Do you understand that you have an
obligation here to tell the truth?
THE WITNESS: Yes, sir.
THE COURT: All right.
LLOYD RAYMOND LONG,
called as a witness in his own behalf, having been first
duly sworn, was examined and testifies as follows:
DIRECT EXAMINATION
BY MR. BECRAFT:
Q State your name, please.
A Lloyd Raymond Long.
Q You're the defendant in this case, right?
A Yes, sir.
Q Are you married?
A Yes, sir.
Q What's your wife's name?
A Dana, D-a-n-a. Named after her father, Dan.
Q She's the lady back here in the red sweater,
right?
A Yes, sir.
Q Do you have any kids?
A Got two children.
Q And they are!
A Kelly is 18, my son, and my daughter is 15,
Wendy.
Q And they're here?
A Wendy is not. She had to have some pictures
made today at school.
Q Now, Mr. Long, I'd like to ask a few basic
questions about your background.
A All right.
Q Can you tell the jury about when you were born,
where, what type of schooling you've had, you know,
elementary and high school?
A Sure. Like I say, I'm Lloyd Long. I was born
in Winchester, Tennessee, which is west of here, just across
Monteagle Mountain. I grew up in a little community, little
farming community called Alto, went to a little
three-teacher elementary school where our principal had --
we knew what the golden rule was, but; he had one other rule.
He said, "Just do right." That was his rule.
So, went on from there to Franklin County High
School, where I majored in agriculture. I met my wife in
high school. We graduated. As I recall, we were king and
queen of the Harvest Festival. That was fun, you know.
We went on from there to --
Q Can I stop you right there? When did you
graduate?
A 1966.
Q All right. And you were born in '48, right?
A '48.
Q So, you're what right now, agewise?
A Seventeen. Oh, you mean --
Q Right now.
A I'm 45. I'm sorry.
Q I didn't catch that.
A There's too many times here.
Q Okay. When you graduated from high school what
did you do?
A Went to MTSU college.
Q From what year to what year?
A From '66 through '72.
Q Did you obtain any degrees?
A I graduated from MTSU in 1970 with a bachelor's
degree, with a major in agriculture and a minor in
industrial education.
Q What did you do -- that was in '70?
A '70.
Q What did you do after then?
A Well, my wife also graduated with a teacher's
degree in elementary education. So, she took a job there in
Murfreesboro, and I stayed and worked on my master's. Then
I graduated from MTSU with a master's degree, or MAT, master
of arts and teaching degree, in 1972.
Q I didn't -- this is my fault. You just said
you were married at that time, right?
A We got married in our junior year. We dated
for six years.
Q So, that would be in what, '69?
A '69, '68.
Q Now, after you got your master's degree, can
you tell the jury basically what you've done, various jobs,
where you've lived, since then, all the way up through
today?
A We left MTSU and I took a job in Sumner County,
which is Hendersonville, which is Johnny Cash country. And
I was hired to set up the first trades and industrial
program in Hendersonville High School and in all of Sumner
County. That was when the vocational education was just
coming into Tennessee, and especially in a lot of counties
they were building comprehensive schools. So, we moved to
Hendersonville. I set up the program there. Taught there
for one year.
I got an opportunity then to transfer to
Gallatin, which is still in Sumner County. And at this
particular point I got the opportunity to write the
specifications and order all the equipment for the new shop
that they were putting in at the new high school, which for
a shop teacher that's a dream because you get to order the
kind of equipment you want. You get to order everything.
So, the next year I moved to Gallatin and set
up that program. And somewhere in that period of time my
son was born. And I taught there for about four years,
which is five years total. And as my little boy got older,
I think he was about three, we were living in a subdivision.
And growing up in the country like I did, I felt the need to
move back home. I wanted him to have the opportunity to
grow up in the country like I did.