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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 degree
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