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Mr. Jackson, testified that petitioners' books and records
were at least as complete and accurate as his other farmer
clients'. However, petitioners never turned their books
and records over to the revenue agents in an organized
fashion as requested and introduced only one page of
their 1987 ledger and all pages of their 1988 ledger into
evidence. Petitioners did not introduce any documentary
evidence of their record-keeping practices for the
remainder of 1987 or 1989 through 1991. Petitioner also
testified that petitioners sometimes paid farming expenses
with checks from their personal bank accounts. Moreover,
petitioners conceded that one check entered on their 1987
ledger as a farm expense and two entered on their 1988
ledger as farm expenses were actually used to pay personal
expenses. Respondent's agent testified that petitioners'
books and records were generally poor compared to those
maintained by the other farmers he had audited, and we find
his testimony credible. On the basis of the record of this
case, we cannot find that petitioners maintained complete
and accurate books and records.
We note that petitioners planted different row crops
in 1988 from those cultivated in 1987, purchased bins to
store grain, erected fences and gates to keep neighbors'
cattle off their land, installed aerators and other devices
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