Anthony G. and Shirley A. Olbres - Page 47

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          courses in business or accounting, around 1975 Mr. Dennett                  
          created the format for, inter alia, the cash receipts journals              
          for petitioners and showed Ms. Olbres how to maintain those                 
          journals.  We are incredulous that Ms. Olbres did not understand            
          the meaning of the title "cash receipts journal".  On the record            
          before us, we reject petitioners' explanation that it was Ms.               
          Olbres' negligence, and not petitioners' fraudulent intent, that            
          was responsible for the 1986 underpayment and the revised 1988              
          underpayment.                                                               
               We turn now to petitioners' claim that although they pro-              
          vided complete written information to Mr. Dennett from which he             
          could have prepared accurate returns for the years in question,             
          he made errors in those returns, which resulted in the 1986                 
          underpayment and the revised 1988 underpayment.  To support their           
          claim, petitioners rely on their testimony.  On the record before           
          us, we are unwilling to accept petitioners' explanation at trial            
          of the reasons why the returns in question reflected the 1986               
          underpayment and the revised 1988 underpayment.  By way of                  
          illustration of the questions we have about the reliability of              
          Ms. Olbres' testimony, she testified about the length of the                
          appointments she had with Mr. Dennett in order to have him                  
          prepare petitioners' returns for the years at issue.  Specifi-              
          cally, she indicated at trial that she made an appointment with             
          Mr. Dennett, she went to each of those appointments, she "[sat]             
          down for a minute" with Mr. Dennett to review some of petition-             




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