- 48 -
ers' deductions, and she then left his office. Ms. Olbres'
testimony about the length of her appointments with Mr. Dennett
in order to have him prepare petitioners' returns at issue is
contradicted by other evidence in the record, including the
testimony of Mr. Olbres and Ms. Dennett. Mr. Olbres testified,
inter alia, that, in order to have Mr. Dennett prepare petition-
ers' returns for the years at issue, Ms. Olbres and he "would go
to * * * [Mr. Dennett's] office, we would sit down, he would
start a piece of paper and a tape and he'd [sic] ask questions"
of petitioners. Ms. Dennett testified that she reviewed Mr.
Dennett's appointment book relating to his meetings with peti-
tioners in connection with his preparation of their returns for
the years at issue and that that book showed that Mr. Dennett met
with petitioners for approximately three hours regarding his
return preparation for petitioners for each of those years.
By way of further illustration of the questions we have
about the reliability of Ms. Olbres' testimony and to illustrate
similar questions we have about Mr. Olbres' testimony, each
testified that, in connection with Mr. Dennett's preparation of
the returns in question, they provided Mr. Dennett with complete
written materials from which he could have prepared accurate
returns. That testimony is contradicted by other evidence in the
record. Mr. Kaply testified that Mr. Dennett informed him that,
in preparing petitioners' return for each of the years at issue,
Mr. Dennett met with Ms. Olbres shortly before each such return
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