- 49 -
was due, she verbally related to him the figures to be used in
each of those returns, and gave him the 1987 summary in connec-
tion with his preparation of their 1987 return. Mr. Dennett
placed those figures on the appropriate lines in each of those
returns and made the computations called for by each such return.
Mr. Kaply further testified that Mr. Dennett advised him that
petitioners never provided him with any bank statements or bank
records in connection with his preparation of any of petitioners'
returns for the years at issue.
Ms. Dennett's testimony supports Mr. Kaply's testimony
regarding what, if any, materials petitioners provided to Mr.
Dennett in connection with his preparation of their return for
each of the years at issue. She testified that one of her duties
in Mr. Dennett's accounting office was to ensure that written
materials that clients provided to Mr. Dennett's office for use
in the preparation of their returns were returned to those
clients upon completion of that return preparation. Ms. Dennett
further testified that she never saw written materials, such as
ledgers, bank statements, and invoice logs belonging to petition-
ers and relating to the years at issue, which had to be returned
to them.
The preparation of the reconstructed 1987 return by Mr.
Dennett and Ms. Wildes also calls into question the testimony of
Ms. Olbres and Mr. Olbres that they gave complete written materi-
als to Mr. Dennett from which he could have prepared accurate
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