- 17 -
was carried on in cash. No records were kept. Mr. McGirl
testified that "an ideal trip for me would go - - would be to
leave the Twin Cities empty, if it [the auction] was out of town,
and to buy, clean, fix, and sell on the road then come back
empty-handed except, of course, with money." Mr. McGirl
testified that some of the money would be spent on supplies,
meals, motels, and gasoline for the automobile. The money left
over was supposedly given to Mrs. McGirl, who deposited it into
the business checking account. Mr. McGirl further testified that
the business was carried on for all of the years at issue. Mrs.
McGirl did not testify concerning this business. Other than the
fabricated auto logs and his own self-serving testimony, Mr.
McGirl offered no proof of the business' existence.
b. Purported Loans From Mr. McAllister
Mr. McGirl testified that he borrowed7 a total of $73,500
from Mr. McAllister, a longtime friend. According to a computer-
generated summary produced by Mr. McAllister after the start of
the MDR audit, Mr. McGirl borrowed money from him 101 times
between September 1988 and March 1991. The amounts supposedly
borrowed were in either $500 or $1,000 amounts, with two
exceptions. Mr. McGirl and Mr. McAllister testified that the
loans were always in cash. According to Mr. McGirl, he borrowed
money from Mr. McAllister before each "auction" trip because he
7 The use of the words "borrowed" and "loan" are for convenience
only and do not reflect a finding that any loans existed.
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