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were the amount received, less what she had "paid out" to other
employees and had paid for breakage and the like. The difference
in what she showed on her records and the amounts determined by
respondent with only these adjustments is difficult to determine
from this record. However, if petitioner had kept the records to
substantiate all items she paid from tips, the difference might
have been relatively small. For a person of petitioner's
understanding of bookkeeping, she kept a reasonable set of books.
Petitioner explained that she now kept better records showing all
items separately. She stated that she now accounts for the total
amount which comes into her hands as tips. From her testimony,
apparently she started her new system after the revenue agent
called her attention to inaccuracies in the system she was using.
However, in our view, petitioner followed what she understood the
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Last modified: May 25, 2011