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respect to those issues. Petitioners introduced no evidence into
the record with respect to the additions to tax under sections
6651(a) and 6654.
With respect to the testimony of Gary Gaffner, we found his
testimony to be general, vague, conclusory, and/or confusing in
certain material respects. We are not required to, and we shall
not, rely on Gary Gaffner’s testimony to establish petitioners’
respective positions on the issues that remain in these cases.
See Lerch v. Commissioner, 877 F.2d 624, 631-632 (7th Cir. 1989),
affg. T.C. Memo. 1987-295; Geiger v. Commissioner, 440 F.2d 688,
689-690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
With respect to petitioners’ document, we found that docu-
ment to be for the most part nothing more than a conclusory
document reflecting the respective positions of petitioners on
the various issues (except for the additions to tax) that remain
in these cases. Although petitioners’ document establishes that
during 1996 Mr. Gaffner and/or Ms. Gaffner paid certain amounts
that petitioners are claiming as deductions for that year, that
document does not establish the respective purposes of those
payments.3 We are not required to, and we shall not, rely on
3In this regard, Ms. Gaffner made some of those payments
during 1996 to certain attorneys. However, neither petitioners’
document nor the testimony of Gary Gaffner establishes the nature
of the legal services performed and/or the nature of the expendi-
(continued...)
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