- 27 - however, did not finish high school, and Jack attended only 3 weeks of college. Neither has any training in business record keeping. Respondent has failed to show clearly that petitioners’ unsatisfactory bookkeeping practices were the result of fraudulent intent. Respondent also criticizes petitioner’s practice of submitting a one-page summary of receipts and expenditures to Jack’s accountant, an old friend from Florida, as a basis for preparing petitioners’ tax returns. The accountant testified credibly, however, that after respondent’s examination commenced, he reviewed certain of petitioners’ records and was able to tie business expenses reported on petitioners’ returns to invoices contained in the records. We also have taken into account testimony of respondent’s agent that the 1993 used-car dealership records she examined closely substantiated the income reported on petitioners’ 1993 return and that the construction business yielded little income. We further note that respondent’s agent did not examine the records for 1994 and 1995. Respondent contends that petitioner’s records do not necessarily reflect off-the-books income that is reflected in the net worth analysis. Respondent, however, has not demonstrated any specific instances wherein any such income was omitted or wherein the records were otherwise falsified. Respondent’s examining agent testified that she believed the unreported income indicated by the net worth analysis was attributable toPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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