Kathleen A. Brown - Page 16

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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