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Personal records kept for business reasons may be able to qualify. A housekeeper's records kept neatly and accurately for purposes of balancing bank statements, keeping strict budgets and preparing income tax returns could qualify under the statute.' The reliability usually found in records kept by business concerns may be established in personal business records if they are systematically checked and regularly and continually maintained. See United States v. Hedman, 7 Cir., 1980, 630 F.2d 1184, 1197-1198 (diary of payoffs by extortion victim); United States v. McPartlin, 7 Cir., 1979, 595 F.2d 1321, 1347-1350 (desk calendar-appointment diary, and cases there cited); Weinstein, supra, (reliability determined from 'testimony indicating that they were kept meticulously'); Advisory Committee Note to Rule 803(6). But see Buckley v. Altheimer, 7 Cir., 1946, 152 F.2d 502, 507-508 (private financial diary inadmissible, distinguished from 'account books or individual memoranda of particular transactions'), a case decided before the adoption of the Federal Rules of Evidence.
