- 46 - prepared correct returns for those years, but did not. Petition- ers are willing to share some responsibility for what they claim are Mr. Dennett's errors in preparing their 1986 and 1988 re- turns. For example, they admit that the cash receipts journals that they claim to have given to Mr. Dennett in connection with his preparation of those returns may have been misleading because those journals did not reflect all of Design Consultants' and/or White Star's receipts. However, they maintain that any errors in those journals, which Ms. Olbres was responsible for maintaining, would have been due to her negligence, and not due to her intent or the intent of Mr. Olbres to commit fraud. We turn first to petitioners' contention that Ms. Olbres may have been negligent, but not fraudulent, in maintaining the cash receipts journals. Petitioners claim, among other things, that any errors in maintaining those journals arose because Ms. Olbres was inexperienced and untrained in maintaining the cash receipts journals and because she had certain unidentified distractions. For example, Ms. Olbres claims that she did not understand that the title "cash receipts journal" was no longer accurate when she stopped recording all of Design Consultants' and/or White Star's receipts in the cash receipts journals that she maintained and instead recorded in those journals only their respective receipts that were deposited into the Indian Head business checking account. On the record before us, we are unwilling to accept petitioners' explanations. Although Ms. Olbres took no collegePage: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
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