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did not conceal his assets or the assets of Beck's Liquors. Mr.
Beck did not use secret accounts or fictitious nominees to hide
his sources of income. Mr. Beck turned over to respondent all
records that he was aware of at the relevant times and thought
were pertinent to the tax returns.
4. Failure To Keep Adequate Books and Records
Mr. Beck's failure to keep adequate books and records
resulted in large part from his failure to seek professional
bookkeeping and tax advice, his lack of bookkeeping training, and
the unusual and tragic circumstances surrounding Mrs. Beck's
death. Mrs. Beck was killed in a car accident in July 1991. As
Mr. Beck explains:
The years 1991-93 were years of trama [sic]. My
wife and I were in an auto accident in which we struck
a moose on the interstate. The top of our car was
taken off. My wife was driving and was decapated
[sic]. Unless someone has seen your wife and best
friend of 38 years bleed to death and die in front of
your eyes, I don't think that you could be thinking
about keeping a great set of books. She had done the
bookkeeping up to that time. * * *
On the entire record, petitioners' books and records are not
inadequate as a result of fraud.
5. Dealing in Cash
Although Mr. Beck may have conducted many transactions in
cash, there is no indication that he tried to hide or conceal any
of these activities. His property purchases and banking
activities were appropriately documented. There is no evidence
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