- 40 -                                         
          himself as unsophisticated or careless with respect to                      
          recordkeeping.  The evidence, however, belies the notion that               
          petitioner was an unskilled or indifferent recordkeeper.  The               
          bookkeeper for his condominium development company credibly                 
          testified that when she raised questions concerning whether the             
          company should pay what were clearly invoices for yacht expenses,           
          she was not only specifically ordered by petitioner to pay them,            
          but was further instructed as to the specific ledger accounts in            
          which to record the expenditures so that they would appear to be            
          expenses incident to the construction or maintenance of the                 
          condominiums.  The evidence shows that petitioner was a                     
          knowledgeable, but deceitful, recordkeeper.  Cf. Korecky v.                 
          Commissioner, supra (rejecting claim of recordkeeping                       
          inexperience as fraud defense).                                             
               Petitioner also claims that he was distraught and mentally             
          impaired during 1995 and 1996, due to the breakup of his marriage           
          and his conviction for felony forgery.  Putting aside the fact              
          that this claim does not address 1994 or 1997, we reject it                 
          because it is contradicted by substantial evidence.  During the             
          claimed impairment, petitioner was operating three successful               
          businesses in two States, generating more than $3.5 million in              
          revenue.23  During the years in issue, he also negotiated the               
               23  WDI reported gross receipts of $1,342,216 and $1,624,352           
          in 1995 and 1996, respectively.  Petitioner admitted to gross               
                                                             (continued...)           
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