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Both petitioners and respondent rely on testimonial and
documentary evidence to support their respective positions in
this case. Mr. Olbres and Ms. Olbres testified at trial.
Although they were able to recollect, understand, and recount
certain details about the multimillion dollar business which they
controlled during the years at issue, they had difficulty in
remembering, comprehending, and/or recounting details about that
business that do not appear to support their position in this
case. We found Mr. Olbres' testimony to be questionable, implau-
sible, and/or vague in certain material respects. We found Ms.
Olbres' testimony to be questionable, evasive, vague, implausi-
ble, and/or conclusory in certain material respects. Under such
circumstances, we are not required to, and we generally do not,
rely on the testimony of either petitioner. See National Fire-
works v. Commissioner, 243 F.2d 295, 297 (1st Cir. 1957), affg.
T.C. Memo. 1956-1; Tokarski v. Commissioner, 87 T.C. 74, 77
(1986).
Ms. LaPlante testified for petitioners. While we have no
reason to question her credibility based on our observation of
her demeanor, for the reasons discussed below, we are unwilling
to rely on her testimony to support petitioners' position in this
case.
Ms. Dennett and Mr. Kaply also were witnesses at trial. We
found Ms. Dennett's testimony to be credible. We also found Mr.
Kaply's testimony to be credible, and we rely on him to establish
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