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accuracy, does not excuse their negligence. None of the
adjustments to petitioners' taxes at issue herein, or the
deficiencies resulting therefrom, derive from expenses deducted
in the wrong year. After reviewing the entire record, including
petitioners' persistent claims to substantial deductions for
items that plainly represent their nondeductible living expenses
and also petitioners' failure to substantiate claims, we are
convinced that petitioners' deficiencies for 1989, 1990, and 1991
are the result of negligence. Respondent is sustained on this
issue.
Petitioners raised several other questions in their post-
trial briefs which we address summarily. First, the notice of
deficiency was timely with respect to all 3 years.3 Second, the
deficiency notice was not arbitrary and excessive. Pasternak v.
Commissioner, 990 F.2d 893, 897 (6th Cir. 1993), affg. Donahoe v.
Commissioner, T.C. Memo. 1991-181; Campbell v. Commissioner, 90
T.C. 110, 115 (1988). Third, petitioners failed to provide any
evidence that they were subjected to unnecessary examination or
investigations, or that if they were subjected to multiple
examinations for the same taxable year, that they objected
thereto. Fourth, petitioners are not entitled to a refund for
3 Petitioners formally extended the time to assess their
Federal income tax for taxable year 1989 to anytime on or before
Oct. 18, 1994. The notice of deficiency was issued prior to Oct.
18, 1994, and within the 3-year limitations period with respect
to taxable years 1990-91. Secs. 6501, 6503.
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