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the testimony of petitioners' witnesses to be credible and
decline respondent's invitation to dismiss it as "simply
the unsupported self-serving testimony of petitioners."
In this regard, we note that, as of the time of trial,
Ms. Ruble had no ongoing business or other connection
with petitioners or her former employer, Mr. Whittington.
The problem with petitioners' evidence, however, is
that it does not go far enough. Petitioners have shown
that for the year 1988, after making reasonable inquiry
of petitioner's former law firm and petitioner's cattle
feeding business, petitioners' accountants estimated
petitioners' income from those activities. According to
petitioners: "These two items alone accounted for more
than the difference between the amount of tax shown due on
the 1988 return and the amount of tax estimated on Form
4868 for 1988." In effect, petitioners have limited their
case to showing the reasonableness of their estimated tax
liability for 1988, $1,408, as compared to the total tax of
$96,418 reported on their 1988 return. Petitioners have
not addressed the adjustments determined in the notice of
deficiency, as revised by the agreed computation of the
1988 deficiency, on the basis of which their total
tax liability is $175,686, or $79,268 more than the tax
reported on their return. Nor have petitioners shown any
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