- 21 - Despite the large difference in ounces of liquor purchased, petitioners’ accountant presented this comparison for the first time at trial. Furthermore, petitioners’ argument is based solely on taxable year 1992. At trial, petitioners’ accountant testified that he had made a similar analysis for 1993, but petitioners did not seek to introduce the accountant’s 1993 analysis into evidence. In their opening brief, petitioners assert: “Although the DABT audit was not extended beyond 1993, the 1992 comparison of alcohol purchases testified to by the Petitioners’ accountant indicates that the revenue agent’s calculation of unreported income is unreliable.” Thus, it appears that petitioners are implicitly arguing that the revenue agent overstated the amount of alcohol purchased in 1993 and 1994, as well as in 1992. Furthermore, petitioners have shown no reason to believe that the DABT Summary of Purchases would yield a more accurate amount of alcohol purchased than petitioners’ own purchase records. In fact, the opposite appears to be the case. If we take the total dollar amount of liquor purchases during 1992 from Crabtree Investments’ general ledger and the gallonage of liquor purchased in 1992 by Justins as reported in the DABT Summary of Purchases, thePage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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