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A There were statements issued for I’m not sure
of the time frame. My guess is ’95, 6, 7. Maybe I’m
wrong but I think maybe ’98. And after that I left and
I don’t really know what took place. But financial
statements were being issued--were issued.
* * * * * * *
Q Okay. Was a general ledger prepared as a
result of this effort?
A Yes.
Such testimony hardly instills a resounding confidence in the
reliability of these documents.
Furthermore, even as to those items for which the record
contains some form of invoice or receipt, those documents in and
of themselves and absent any additional explanation from
petitioners are often insufficient to establish all requisites
for the treatment claimed. Likewise, for the particular
expenditures that petitioners do touch on in the testimony
offered, their brief statements typically fall far short of
addressing all pertinent requirements for allowance.
Hence, while the Court has dealt with the record presented,
we are left with the overall impression that petitioners have
chosen to bank on a rather haphazard, big-picture, almost all-or-
nothing approach in lieu of the item-by-item documentation or
detail we would have expected for issues of this nature.
B. Burden of Proof
Against the foregoing backdrop, the Court addresses the
parties’ contentions regarding burden of proof. As a general
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