Joseph A. and Sari F. Deihl - Page 11

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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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