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expenses, and expenses of attending seminars. Petitioners bear
the burden of proving that they are entitled to deductions. See,
e.g., Rockwell v. Commissioner, 512 F.2d 882 (9th Cir. 1975),
affg. T.C. Memo. 1972-133.
It is apparent from the record in this case that petitioners
are not entitled to the benefits of the burden of proof
provisions of section 7491(a). They have failed to respond to
reasonable requests for information, documents, meetings, and
interviews, and they have failed to comply with Court orders that
they produce documents and answer questions. They have not
presented any substantiation with respect to deductions for 1996
and 1997. They have not produced credible evidence on disputed
issues of fact. In view of their history as tax return
preparers, they should have been familiar with the types of
records required and the legal requirements for deductions.
Instead of substantiating their deductions, they have made
unwarranted accusations against those charged with determining
their tax liability.
Mr. Nordbrock testified only after the Court told him that
he would have to explain the documents that had been produced for
1995 before any deductions could be allowed. His testimony was
vague and conclusory and marked by failure to remember specific
details on cross-examination. Ms. Nordbrock declined to testify.
Petitioners contend that the bankruptcy proceedings were
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