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1963-333. We understand that some portion of Kenmore’s records
had been stolen in 1986, and this was at least partially
responsible for petitioners’ inability to produce complete
records at the trial. However, the records that were produced,
and the testimony of Bohn, Gleave, and Broskin, convince us that
the records never were adequate to track through the maze of
Kenmore’s activities and assets. Thus, the 1986 theft does not
affect our conclusions on this point.
Kenmore’s failure to make and keep adequate records, in the
context of the instant cases, is significant evidence of fraud.
(d) Implausible Explanations
Gleave’s determination to run his financial activities
through Kenmore--both with regard to Kenmore’s Account and the
cash in the safe at the Kenmore location--led to many of the
record-keeping confusions that may have inspired several of the
implausible explanations that petitioners offered in attempts to
bridge the substantial gap between (1) the total deposits into
Kenmore’s Account and (2) the gross receipts reported on
Kenmore’s tax returns.
Thus, petitioners contend that more than $170,000 of the gap
resulted from Gleave’s deposits into Kenmore’s Account--$100,000
from the Ted’s Nursery sale and $70,000 from the apparent
inheritance. As we explained (supra, (a) Gross Receipts), we are
satisfied that: (1) If any such deposit occurred after the Ted
Nursery sale, then it did not affect more than $6,600 of the gap
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