Raymond Strong - Page 20

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          1987, and that petitioner paid for them, but petitioner’s diary             
          shows Wright as a guest only once.  Sullivan went to lunch with             
          petitioner many times, but not to dinner, during 1987;                      
          petitioner’s diary shows Sullivan as petitioner’s guest for four            
          dinners and only three lunches.  Petitioner’s diary shows 11                
          dinners at Frank’s Steak in 1987; 9 were purportedly                        
          substantiated by stubs.  However Frank’s Steaks did not open                
          until July 1988, and the predecessor restaurant, The Peculiar               
          Penguin, closed in January 1987.  Also, the stubs petitioner                
          presented to substantiate the Frank’s Steaks business meals were            
          of a style that had never been used by either Frank’s Steaks or             
          The Peculiar Penguin.  In addition, our findings set forth                  
          numerous inconsistencies among the stubs.                                   
               Petitioner’s cause is not helped by his testimony that he              
          relied on stubs that he filled in, even where he had paid the               
          bill by credit cards and thus had credit card receipts.  He                 
          testified that the stubs that he filled in were just as                     
          trustworthy as credit card receipts.                                        
               The record does not include meaningful evidence to                     
          corroborate the reliability of petitioner’s diary or stubs.  Nor            
          has petitioner offered as adequate explanation for the                      
          inaccuracies and inconsistencies which are identified with                  
          respect to the diary and stubs.  Based on the record, we                    
          conclude, and we have found, that petitioner’s diary and the                






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