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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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