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amount of cash they wanted and the denominations thereof. Based
upon these written instructions, petitioner obtained cash from
the Amarillo National Bank. Petitioner placed the cash requested
by each vendor in a separate bank bag supplied by the Amarillo
National Bank. The bank bags were identified by a number
assigned to the individual vendors. Immediately before the shows
began, petitioner made the bank bags available to the vendors at
a central location. Each vendor was required to sign for the
bank bag at the time it obtained its requested cash. At the
conclusion of the food shows, the vendors returned to petitioner
the bank bags and any unused cash. Petitioner maintained a
record of the amount of cash given to each vendor, the source of
that cash, and the amount of any cash returned to petitioner at
the conclusion of the food show.
As indicated above, each page in the food-show book had a
perforated tear strip. At the food show, representatives of the
member stores placed their merchandise orders on the tear strip
and turned them into the vendors. The vendor made the product
promotional payments, then gave the tear slip to petitioner.
Subsequently, petitioner would order the merchandise, deliver it
to the member stores, and bill the member stores. The tear
strips had the amount of the product promotional allowance on
them. However, petitioner destroyed these records.
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