Haralampos Katerelos and Irene Katerelos - Page 28

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            1992, and 1993.  In those returns, petitioners reported gross                                 
            receipts and net profit of NDV and total gross income, as fol-                                
            lows:                                                                                         
                  Gross Receipts    Net Profit                                                            
                  Year        of NDV          of NDV      Total Gross Income                              
                  1990      $372,332         $25,647           $22,626                                    
                  1991       365,611          21,076            18,861                                    
                  1992       396,801          38,694            42,614                                    
                  1993       439,578          65,425            65,425                                    
            Petitioners' Expenditures and Other Relevant                                                  
            Admissions During the Years at Issue                                                          
                  In a residential loan application signed by petitioners                                 
            during December 1987, petitioners indicated that their monthly                                
            gross income was $5,000.  Petitioners' monthly mortgage payment                               
            after securing that loan was $887.27.                                                         
                  In an application for casualty insurance for NDV that Mr.                               
            Katerelos signed and that is dated April 8, 1988, he stated that                              
            NDV had annual sales of $360,000.                                                             
                  During 1987, petitioners made $29,000 of improvements to the                            
            residence that they had purchased in 1986.  A list of those                                   
            improvements appeared in NDV's gross receipts journal for 1987 at                             
            the time in 1990 that that journal was provided to Mr. Phielix                                
            during respondent's examination of petitioners' returns for 1987                              
            through 1989.  One week after he returned that journal to peti-                               
            tioners and confronted them with the list of improvements, Mr.                                
            Phielix reviewed the journal again and noticed that that list was                             
            missing.  Mr. Katerelos had torn that list out of the gross                                   




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