- 11 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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