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products. Ms. Rhodes stated that C.O. was a Frank’s employee
whose name was Chloe. At trial, several employees and managers
of Frank’s testified that the purchase orders presented by Ms.
Rhodes were not from Frank’s, the store only sold items wholesale
from corporate headquarters, and the locations from which Ms.
Rhodes stated she bought the supplies did not have enough cash
receipts on the days in question to support purchases in the
amounts petitioners claimed. Additionally, the corporate human
resources manager for Frank’s during the years in question
testified that he and another human resources employee verified
that no Chloe, Chloe O., or C.O. had ever worked at the Frank’s
locations where Ms. Rhodes claimed she made her purchases.
Although Ms. Rhodes told the examiner that all her purchases
were made inside the Frank’s store, she testified at trial that
she purchased her merchandise in the parking area of the store
off the back of a large truck that was attended to by Chloe, whom
she believed was a Frank’s employee. She testified that,
although Frank’s had refused to sell merchandise wholesale to
her, Chloe approached her and offered to sell the merchandise to
her at wholesale prices. Ms. Rhodes claimed that Chloe would
call her whenever a new “shipment” arrived and then she would
meet Chloe in the parking lot of Frank’s and complete the sale.
Chloe dealt only in cash and gave Ms. Rhodes a Frank’s purchase
order at the end of each transaction. Ms. Rhodes testified she
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