Daniel R. Leavell and Eva Lovene Leavell - Page 8

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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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