- 13 - 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 generalPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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