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their 1993 amended return), Mr. Grenville-Jones testified that
petitioners provided him with, inter alia, (1) certain documenta-
tion with respect to the alleged business use of petitioner's
Ferrari; (2) the 1993 receipt book; (3) a ledger that contained a
list of the equipment that petitioner claimed to have used in his
automobile repair activity and the estimated values of that
equipment; (4) certain receipts; (5) three estimates related to
the 1994 Northridge earthquake; and (6) a list of property that
petitioners alleged was damaged in the 1994 earthquake. We note
initially that although Mr. Grenville-Jones testified about
certain documents that petitioners provided to him, not all of
those documents are in the record. With respect to those docu-
ments about which Mr. Grenville-Jones testified and which are in
the record, petitioners did not testify, and we do not know, when
those documents were prepared or whether they are complete and
accurate. We have found that petitioners have not established
through those documents that they are entitled to the deductions
that they claim.
It is also significant to any contention by petitioners that
they are not liable under section 6662(a) because they relied on
Mr. Grenville-Jones that Mr. Grenville-Jones testified that he
has a bachelor's degree in engineering and electronics and a
master's degree in electronic engineering. In addition, although
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