- 13 -
by circling any overring transaction on the cash register tape.
However, the transaction total of every transaction entered into
the cash register for a day, including any overring transaction,
was reflected in the total sales for that day.14 To correct that
problem, when a transaction was circled as an overring on the
cash register tape that Mr. Katerelos saved for a particular day,
Mr. Katerelos subtracted the transaction total of any such
transaction from the amount of daily total sales according to the
Z reading on the cash register tape that he saved for that day
and entered the balance as the amount of NDV's daily gross
receipts that he recorded for that day in the gross receipts
journal.
For approximately 10 days during the years 1987 through
1990, Mr. Katerelos saved cash register tapes that showed two Z
readings. The first Z reading on such a tape resulted from Mr.
Katerelos' having activated the Z or reset mode after an error
(that may or may not have been an overring) had occurred during
the day in entering a transaction into the cash register. After
14 In addition, the transaction number was increased by one as a
result of any overring transaction, and the grand total as of
that day was increased by the transaction total of any overring
transaction. Although Mr. Katerelos did not use the grand totals
to determine the amount of NDV's gross receipts that he recorded
for a particular day in the gross receipts journals, as discussed
below, respondent's revenue agent used the grand totals to
determine the amount of NDV's gross receipts for the years at
issue, and, in calculating those gross receipts, he made appro-
priate adjustments for any transactions that were or were treated
as overrings.
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