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deficiency involved nearly a hundred adjustments, and the parties
are to be commended for substantially narrowing the categories
that remain at issue. Nevertheless, a few preliminary comments
about the status of the record are in order.
Despite the above-mentioned narrowing of the issues, the
categories that remain in dispute incorporate many dozens of
discrete outlays. The stipulated exhibits alone run well over a
thousand pages. Yet as to a substantial portion of the
individual items claimed, petitioners failed to address the
specific expenditures at trial or on brief. Petitioners’
testimony instead tended to be broad brushed and conclusory in
approach. There is no shortage of blanket testimony resorting to
use of the word “all” in various contexts that the Court is
simply unwilling to countenance at face value. Hence, from a
substantiation standpoint, the Court is apparently expected in
many instances to rely on nothing more than perhaps credit card
statements and the characterizations reflected in the general
ledgers offered by petitioners.
In this connection, and as will become clearer in the
discussion to follow, the Court observes that petitioners’
general ledger categories for expenditures seem to be vaguely
defined, overlapping, random, and self-serving. For example, the
rhyme or reason for labeling what would appear to be similar
outlays as incurred for training, meetings, and/or conventions,
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