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             of $429,421 in 1990 and $1,173,203 in 1991.  Petitioners                 
             acknowledge that "they bear the burden of proof as to                    
             substantiation", but they claim in their posttrial brief                 
             to have substantiated the subject purchases based upon the               
             following grounds:                                                       
                  (1)  All of the disallowed checks "were issued to                   
             individuals or entities that were known tobacco vendors."                
                  (2)  The Forms MQ-79 filed on behalf of Beaufort Leaf               
             "list tobacco pounds for the transactions challenged by                  
             Respondent that correspond to the pounds of tobacco                      
             represented by the disallowed purchases."                                
                  (3)  The subject checks were honored by the banks at                
             which they were presented.                                               
                  (4)  Beaufort Leaf's accountant, Mr. Dawson,                        
             testified that the account payable from Okay Leaf of                     
             $350,000 was for tobacco purchases and that testimony is                 
             corroborated by the Forms MQ-79 which show tobacco                       
             purchases from Okay Leaf in 1991 in excess of $700,000.                  
                  (5)  All available books and records of Beaufort Leaf               
             properly record the disputed transactions as purchases of                
             tobacco.                                                                 
                  We do not agree that petitioners have substantiated                 
             the amounts disallowed by respondent as purchases of                     
             tobacco.  None of the points that they advance prove that                
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