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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 college
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