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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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