eral counsel had demonstrated unlawful motive.166 Likewise, contrary to the contentions of ALFA and AHCA, the Board will not assume that any failure Mike O’Connor Chevrolet, 209 NLRB 701, 703 (1974), enf. denied on other grounds 512 F.2d 684 (8th Cir. 1975). 164 See also comment of American Health Care Association (AHCA