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amended petition, or otherwise preserved. Petitioners’ untimely
attempt herein to raise new issues will be denied.
Taxpayers have a duty to maintain accurate and credible
books and records that relate to their income and deductions for
each year and that are necessary for a proper determination of
their Federal income tax liability. Sec. 6001. As has been
said, "The United States has relied for the collection of its
income tax largely upon the taxpayer's own disclosures * * *.
This system can function successfully only if those within and
near taxable income keep and render true accounts." Spies v.
United States, 317 U.S. 492, 495 (1943). The burden of proof is
on petitioners to prove by a preponderance of the evidence their
entitlement to the deductions, losses, credits, and other
adjustments that are in dispute in this case. Rule 142(a); Welch
v. Helvering, 290 U.S. 111 (1933).
With the exception of a $21,222 trucking expense, discussed
below, petitioners have failed to satisfy their burden of proof
on each issue, and, with the exception noted, we hold for
respondent on each issue. Many of petitioners' arguments in
their posttrial briefs are barely comprehensible. Below, we
attempt to make some sense out of petitioners’ arguments and to
discuss further the sparse and confusing facts in the record
relating to each primary issue.
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