Joseph A. and Sari F. Deihl - Page 13

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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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