- 47 - 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-Page: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
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