- 77 - at 173; Pessin v. Commissioner, supra at 489. Petitioners here have not done so. They have shown neither that they initially gave all requisite information to Mr. Goltz nor that Mr. Leo had available for his use sufficient accurate materials to prepare correct returns. For instance, did petitioners at one time provide to their advisers receipts or invoices that would substantiate the many expenditures for which the record contains no documentary evidence? With respect to those items that were reflected in available receipts or invoices, did petitioners offer to their advisers further explanation, particularly in connection with purchases at retail establishments, as to the intended recipient and/or use of the articles purchased? When they were at conventions, potentially away from their accounting staff, did they maintain documentation of business expenses that arose and carefully segregate any personal purchases? Were the professionals, like the Court, limited in various circumstances to blanket statements that “all” outlays at a certain location or using a particular credit card related to the businesses? What specific information was available to the advisers with respect to the improvements to petitioners’ residence? On this record, the Court simply cannot conclude that petitioners have met the evidentiary burden of the second prong of the test for reasonable reliance. The Court likewise has reservations about petitioners’ compliance with the third prong that flow to a certain degreePage: Previous 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 Next
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