Neil T. Nordbrock - Page 11




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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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