- 20 - 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 thePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011