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example, and the amount of 20 cents, due to misplacement of
the decimal, and some of the tapes had substantial
omissions.
The Respondent spoke to the Petitioner on the telephone
yesterday afternoon * * * and conveyed to her these
conclusions * * * that Respondent would not concede reported
gross receipts amounts for 1989 and 1990.
At the time the parties spoke, Petitioner did not know
whether she would come to Court or not. In any event, the
Respondent has no questions for Petitioner.
The Court, however, would have been interested in hearing
petitioner's testimony regarding these sales tickets and to
explain or address the problems pointed out by counsel for
respondent. Petitioner produced no accounting records that would
corroborate the sales tickets. The tickets alone do not have
that much significance to the Court without testimony explaining
petitioner's accounting methodology and, in particular,
addressing the apparent flaws suggested by respondent's counsel.
The gross receipts reported on the tax returns are admissions by
petitioners, and we generally do not permit the substitution of
lower values in the absence of cogent proof. See Estate of Hall
v. Commissioner, 92 T.C. 312, 337-338 (1989). On this record,
the Court holds that petitioners failed to sustain their burden
of proof on this issue. Respondent, therefore, is sustained.
The second issue is whether petitioners are entitled to a
child care credit for the years 1989, 1990, and 1991.
Petitioners claimed a credit of $960 for each of these years for
two dependent children. Respondent disallowed the credit for
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