Clyde E. Owens and Marie W. Owens - Page 20

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          explanation for each adjustment that respondent made, and they              
          identify the amounts of tax, interest, and penalties due.                   
               Petitioners have only themselves to blame for their                    
          difficulties in these cases.  They had many opportunities to                
          exchange evidence with respondent as required by our orders.                
          Petitioners seemed to think that insulting respondent's agents              
          would enhance their chance of prevailing and excuse their failure           
          to take steps necessary to fully present their cases on the                 
          C.   Whether Respondent's Determination Should be Sustained                 
               1.   Whether Petitioners Had Less Income Than Determined by            
               Petitioners contend that they had less income than                     
          respondent determined.  Mr. Owens testified generally that the              
          Big O businesses did not generate as much income as respondent              
          determined, and that the Big O businesses were small and competed           
          with larger firms.  He did not give any information to support              
          his conclusionary claims.  Mrs. Owens testified briefly.  Her               
          testimony did not show that respondent's determination was                  
          incorrect.  Ms. Feltrinelli did not testify.  We sustain                    
          respondent's determination about the amount of income petitioners           
          received in 1989 and 1990, except as conceded by respondent.                

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